Decision for Littlechild Aggregates Ltd (OF2080840) and Ace Aggregates (OF2078398)
Source: gov.uk (2025-09-12)

Written confirmation of the decision of the Traffic Commissioner for the East of England for Littlechild Aggregates Ltd and Ace Aggregates

IN THE EASTERN TRAFFIC AREA

LITTLECHILD AGGREGATES LTD – OF2080840

AND

ACE AGGREGATES LTD – OF2078398

CONFIRMATION OF THE TRAFFIC COMMISSIONER’S DECISION

Background

Littlechild Aggregates Ltd seeks a Standard National Goods Vehicle Operator’s Licence authorising 3 vehicles only. The Director is Sean Littlechild Jnr, who has nominated himself to the Transport Manager.

That applicant proposes to use The Hanger, Potton Road Tempsford Everton, Sandy SG19 2JW as the Operating Centre. Preventative Maintenance Inspections were to be carried out by Ace Fleet Maintenance Ltd at 6-weekly intervals.

Ace Aggregates seeks a Standard National Goods Vehicle Operator’s Licence authorising for 6 vehicles and 3 trailers, subsequently varied to 1 vehicle and 2 trailers. The Director is Suzanne Littlechild. The applicant has now nominated Harnik Midder to act as the Transport Manager. Mr Midder is already named as the Transport Manager on OF2056445, a Standard International Goods Vehicle Operator’s Licence held by Intercargo Ltd and authorising 2 vehicles and 5 trailers. He apparently dedicated 45 hours per week as an internal Transport Manager (but see below).

That applicant proposes to use Newton Grove Farm, Sutton Road, Dunton Biggleswade SG18 8RA as the Operating Centre. Preventative Maintenance Inspections are to be carried out by R D Woodcraft Ltd and Renault Chiltern at 6-weekly intervals, but that was changed (see below).

Hearing

The hearing was listed for today, 28 August 2025, in Tribunal Room 1 of the Office of the Traffic Commissioner in Cambridge. The first applicant was present in the form of Sean Littlechild Jnr. The second applicant was present in the form of Suzanne Littlechild, represented by James Backhouse of Backhouse Jones solicitors, and accompanied by Harnik Midder, proposed Transport Manager. Also present was Sean Littlechild Snr, described as an employee, having resigned as a Director in April 2025.

Determination

As per the notice dated 5 June 205, the hearing was called at the request of the first applicant to pursue its application by showing that it meets the statutory criteria and specifically the following sections of the above Act:
- 13A(2)(b) – good repute including fitness to meet the licence requirements.
- 13A(2)(c) – financial standing and by reference to 13D
- 13A(3) – Transport Manager meeting Schedule 3
- 13C(2) – satisfactory arrangements for complying with drivers’ hours requirements.
- 13C(3) – satisfactory arrangements to ensure vehicles are not overloaded.
- 13C(4) – satisfactory arrangements and facilities for maintaining vehicles in a fit and serviceable condition.
The public inquiry was called at the request of the second applicant to pursue its application by showing that it meets the statutory criteria and specifically the following sections of the above Act:
- 13A(2)(b) – good repute including fitness to meet the licence requirements.
- 13A(2)(c) – financial standing and by reference to 13D
- 13A(3) – Transport Manager meeting Schedule 3
- 13C(2) – satisfactory arrangements for complying with drivers’ hours requirements.
- 13C(3) – satisfactory arrangements to ensure vehicles are not overloaded.
- 13C(4) – satisfactory arrangements and facilities for maintaining vehicles in a fit and serviceable condition.
The applicants were directed to lodge evidence in support by 7 August 2025, including financial, maintenance and other compliance documentation.

Determination

At the time of the application Mr. Littlechild Jnr was also named as both a director and TM on application OF2078398, made by Ace Aggregates Ltd, seeking authority to operate 6 vehicles and 3 trailers under a Standard National Goods Vehicle Licence. His mother, Suzanne Littlechild was also named as a director on that application.

Correspondence dated 13 March 2025 sought supporting documentation including further financial evidence in the name of the first applicant, Littlechild Aggregates Ltd. That also referred to Mr Littlechild Jnr’s involvement with the second application by Ace Aggregates Ltd. Mr Littlechild Jnr was asked to explain the links between the businesses and he would meet the statutory duty as Transport Manager, in addition to his responsibilities as a director of both entities.

The response dated 22 March 2025 indicated that, whilst Littlechild Aggregates Ltd had been incorporated on 13 February 2025, it was yet to start trading. It was suggested that the first applicant intended to operate as a specialised aggregate and earth moving contractor, under contract from national and regional distributors. Mr Littlechild Jnr referred to previous work with his father (LTS Haulage Ltd) for 9 years, when he undertook driving duties as well as sales. He now sought an opportunity to run his own business. He stated that he intended to work full-time in connection with Littlechild Aggregate Ltd business including ten hours per week dedicated to the role of Transport Manager and approximately 12 hours to Director duties. Mr Littlechild Jnr now felt that he should devote all his time to this applicant and had therefore, had decided to step down from his appointments with Ace Aggregates Ltd once this application had been granted. He sought interim authority to commence operations as soon as possible. My office subsequently received notification on 8 April 2025 that Mr Littlechild Jnr had ‘with immediate effect… resigned as the transport manager on the application/ licence of OF2078398, Ace Aggregates Ltd’.

By letter of 17 April 2025, my office sought clarification as to whether Mr Littlechild Jnr still acted as a Director for Ace Aggregates Ltd. A response was received the same day, indicating that Mr Littlechild Jnr was still named as a director, but would be taking the necessary steps to relinquish that appointment. Mr Littlechild Jnr was removed as a director on 24 April 2025. This gave rise to concerns because of the manner in which the associated application had been pursued, meaning that Director fitness (an essential element of the company’s repute) remained at issue, as well as his ability to fulfil the role of Transport Manager. The first applicant was put on formal notice.

Mr Littlechild Jnr responded on 6 May 2025, with further detail regarding these two applications. Mr Littlechild indicated that, in late 2024 his father, Sean Littlechild Snr, came to him and expressed his wishes to ‘wind down’ his company, LTS Haulage. Mr. Littlechild Jnr wanted to carry on within the business until it was brought to his attention that the company was in fact being placed into voluntary liquidation. As LTS Haulage Ltd was closing, he was advised by his father to continue within the industry as he had made good connections and built a reputation. He therefore applied for an operator’s licence with Ace Aggregates Ltd.

To assist in meeting financial standing, Mr Littlechild Snr invested in that company. Mr Littlechild Snr wished to remain a ‘significant controller’ until the loan was repaid so his mother, Suzanne Littlechild was appointed a director, to oversee operations. Based on the face of the application documentation, the second applicant sought and obtained second a time-limited interim licence on 4 February 2025, for a period of 3 months. Mr Littlechild Jnr explained that once the interim was granted, it soon became apparent that the family had differing views on how the business should operate with Mr Littlechild Snr realising that ‘it was not his money on the line’ and he would not be making the decisions he want to make, which caused rifts within the family. Following those disagreements, Mr Littlechild Jnr purchased some vehicles (formerly in the name of LTS Haulage Ltd) from the liquidator) and decided to ‘go at it alone.’ It was agreed that Mr Littlechild Jnr would stay on as Transport Manager until the licence for Littlechild Aggregates was granted. However, he became concerned that his name was still on the licence for Ace Aggregates and, as he did not have full control of the operations, decided to resign with immediate effect.

Mr Littlechild Jnr indicated that he would like the opportunity to keep his good repute and in hindsight should have applied for a licence on his own initially as he now understands the potential threat of losing his good repute and it had caused unnecessary rifts within his family. Following an updated proposal to refuse the first application, dated 16 May 2025, Mr. Littlechild Jnr requested a Public Inquiry (21 May 2025) to allow ‘the opportunity to present further evidence and clarification regarding the concerns that led to the refusal of my application’. He communicated his commitment to full compliance with the relevant and regulatory and safety obligations and to resolving all outstanding matters.

Following the resignation of Mr Littlechild Jnr, my office received a TM1 form from the second applicant on 28 April 2025, seeking to nominate Mr Littlechild Snr to act as Transport Manager. As indicated above, Mr Littlechild Snr was previously named on the Standard National Goods Vehicle Licence held by LTS Haulage Ltd, until its revocation on 10 April 2025. My office only became aware of the liquidation on 23 January 2025. That operator was put on notice of the potential consequences under cover dated 15 February 2025. Mr Littlechild Snr then attempted to surrender that licence on 27 February, i.e. after the appointment of the liquidator.

Correspondence dated 29 April 2025 from previous solicitors for the applicant referred to the attempt by Mr Littlechild Snr to surrender the licence belonging to LTS Haulage Ltd. It also sought a Period of Grace on the interim licence to process and consider his nomination as Transport Manager. Further correspondence was received relating to financial standing, notifying me of a voluntary reduction in the authorisation down to the current application for 1 vehicle and 2 trailers. Further bank statements were attached. Formal notice that I remained to be satisfied, as a result of these changes, was sent on 15 May 2025 noting that discretion had been exercised in favour of the second applicant allowing authority for 4 vehicles. The nomination of Mr Littlechild Snr also failed to refer to LTS Haulage Ltd.

The response from those solicitors received on 29 May 2025, requested that the application be reconsidered and requested this hearing. The letter accepted that there would be concerns arising from Mr Littlechild Snr’s appointment and proposed to nominate Harnik Midder to provide an independent oversight of the operations. All of Mr Littlechild Snr’s shares were also transferred to Suzanne Littlechild. It was suggested that ‘it would be absurd to suggest that Snr and his wife will not discuss matters and seek guidance from each other’ due to the family arrangement. However, the applicant offered an undertaking that Mr Littlechild Snr would not have any ‘material/ controlling interest in the business.’ Enclosed was also a letter from Mrs Littlechild describing her experience and in the transport industry since 1992, latterly ensuring compliance for Ace Aggregates. A contract for Harnik Midder’s appointment was also provided but contained limited information going to paragraph 14A(1)(d) of Schedule 3 and suggested that he would visit the operation once a monthly on-site visit, but with up to 6 hours per week of ‘remote compliance oversight’.

My office sent a confirmation of hearing to the second applicant on 5 June 2025, following recent changes in the application. Further correspondence was received on 13 June 2025 from previous representatives. Mr Backhouse’s firm then sought to renew the application for interim authority. It was understood that I would still need to be satisfied that the statutory grounds for holding a licence were met. However, correspondence referred to further changes: an amended contract for services from Mr Midder referring to a weekly site visit and requiring effective and continuous management of the transport operation. I was further informed that Sean Littlechild Jnr was less involved with the second applicant, as he is no longer the majority shareholder, so Mr Midder now provides independent oversight of the operations. The involvement of Sean Littlechild Snr would be limited to that of an emergency driver and would not act as the controlling mind of Ace Aggregates. I determined that these proposals should be scrutinised at this hearing.

The hearing was necessary to establish precisely the intent behind the different applications and who might be responsible for compliance, going forward. I was given a history of the second applicant, dating to May 2023, when that dormant entity was identified by Mr Littlechild Jnr as a potential vehicle to collect different aggregate customers, outside the existing customer base of LTS Haulage Ltd, to sell and broker services, with an intention to eventually sell that business. He told me about the various changes in his family, with a wish to ensure future security. That came to the fore when he learned of the financial difficulties facing LTS Haulage Ltd, which employed him as a driver (following a different career in London). He recognised that he required assistance to realise his business model. Mr Littlechild Jnr would be well advised to seek advice before attempting to realise future business plans (see an example see below).He then involved his parents who invested their money to take the second application forward. He was said to be unhappy when this resulted in only a 20% shareholding in what he believed was his vision. Nevertheless, it was the intention to also realise the goodwill of the original business, namely LTS Haulage Ltd. That led to a family disagreement.

Mrs Littlechild was appointed as Director to protect her interests and those of her husband. I am satisfied that, whilst Mr Littlechild Snr may have become disillusioned with transport for a short period, it was his intention to become closely involved with management, as reflected in the decision to nominate him as Transport Manager after Mr Littlechild Jnr gave notice in February 2025. On his own admission, he had no business experience but has been warned that he needs to ensure compliance with the basic requirements of an operator’s licence. It was admitted that Mr Littlechild Snr will play a more active part in the business and seeks to protect his interests. It is his intention to apply to replace Mr Midder as Transport Manager after a period of 6 months, to allow for processes to bed in. I accepted an undertaking from the second applicant that Mr Littlechild Snr would be appointed as a statutory Director within 1 month of grant.

In the meantime, Mr Midder is no longer subject to full-time commitments on another licence. He needs to ensure that has been notified as a matter of urgency. I have accepted that statement of intent that he will attend for a minimum of 2 hours each week in order to discharge his statutory duties. Ace Logistics Ltd provided a bundle of proposed policies and procedures including an example of a driver defect report apparently using RHA technology, a copy of a blank maintenance contract, a list of annual test and inspection dates, driver licence check policy, proposed infringement and missing mileage reporting, photograph of the RHA dashboard page, training certificates – Drivewise 2-day transport manager refresher for Sean Littlechild attended on 14 and 15 August 2025 (reflecting his intentions to be involved with management) and Operator Licence Awareness training by Voyager Group Consortium for Suzanne Littlechild on 19 June 2025, photograph of Sean Littlechild’s driver licence card, recruitment policy, induction process, disciplinary policy, inspection sheet (which was difficult to understand). Mr Midder was present, despite previous correspondence.

Littlechild Aggregates Limited lodged a series of policy documents: Driver compliance policy, Driver Infringement Review Form, Drivers’ Hours Policy, Employee Declaration form, Fatigue Management Policy, Daily Defect Reporting System, Health and Safety Policy, Disciplinary Policy, Mobile Phone Policy, Preventing overloading policy, Recruitment policy, Tyre Management policy, Vehicle Management Policy, Alcohol and drug use policy, in addition to maintenance contracts, Missing Mileage and infringement reporting, Forward Planner, Safety inspection report.

Both Transport Managers should refer to paragraph 60 of Statutory Document No. 3.

Both applicants had sought to rely on Ace Fleet Maintenance Ltd to inspect at 6-weekly intervals. Companies House referred to that as a mobile operation, but I was assured that there is a fully functioning workshop with three bays, pits and other equipment including a roller brake tester. The first applicant changed its nomination to Heyns Commercials Ltd, at the same intervals. That was described as having 2 bays/under cover pits, with similar facilities.

Concerns were raised by the fact that there appeared to be regular payments from the first applicant to the second. Mr Littlechild Jnr very frankly admitted that the first applicant had been used to provide driver services to G Webb Haulage Ltd. He had been retained as a driver for an indeterminate period exceeding two months. Another driver, employed by the second applicant to undertake double shifts with Mr Littlechild Snr, as part of that operation, had also been supplying driver services through the first applicant, explaining its payments to the second applicant. My concern at these arrangements was conveyed to both applicants, but especially Mr Littlechild Jnr, as his engagement appeared to be more than temporary. That is now a matter of record and will have to be followed up by the Office of the Traffic Commissioner.

Having established the true position, where the actions of both applicants had led to a lack of clarity, and having accepted the undertaking and statements noted above, I was able to grant both applications but with a very clear expectations that there must be full compliance going forward.

R Turfitt

Traffic Commissioner

28 August 2025