Is DVSA’s protectionism stagnating service levels for the end user?

I’ve had various conversations with DVSA, on behalf of members, who have had their testing allocations reduced.
There hasn’t been much in the way of a factual reasoning from DVSA, therefore, the industry generally concluded that they were caught short with the combination of opening over 550 ATF’s in quick succession at the same time a lot of DVSA testers left the service.
Since the big cull in testing quotas across the country, there are still ATF’s, waiting in vain, wanting to expand their operation to meet their original testing quota. There are  many other organisations who have already built fully functional testing bays awaiting DVSA to lift their restriction on new ATF’s.
DVSA maintain that
“ testing allocations are made on the basis of productivity. ATFs are invited to submit business cases to Network Business Managers when winning new contracts or experiencing increases in demand. Network Business Managers will consider all reasonable requests for additional allocations based on evidence.”
In many cases ATF’s delivering 85%-90% + had their testing allocations reduced by up to 50%. I personally had a 25% reduction despite circa 90% to 95% Capacity Utilisation (CU) and never received a factual explanation from DVSA. So their statement about productivity does not hold up.
That aside, there is a strong argument to suggest that the ‘productivity’ method DVSA employ reduces competition and quashes free market activity and therefore creates an ever decreasing testing environment. DVSA’s method is reactive rather than proactive. It protects their supply of testers because it significantly reduces flexibility on demand.
DVSA’s method (to submit a business plan) weighs too much on preserving the ‘norm’ and protecting DVSA from having to react to fluctuations of their ATF partners and their customers choice.
There is little weight, in the existing method, given to reward ATF’s who use a balanced risk approach by requesting more test slots as part of their business growth plans.
I would suggest to DVSA that continuing to employ these methods restricts speculation and competition. The incentive to succeed and offer a better service for your customers  is removed so the market just gets sluggish.
In free markets, a superior service is normally rewarded with more customers, so, high performing ATF’s requesting ‘proactive’ test allocation slots would get them be filled. Punitive measures for over capacity already exist, the ATF is punished with having to pay for slots not filled.
DVSA’s method turns normal competitive free enterprise on its head and treats all ATF’s the same, which is undemocratic and unfair.
The end customer experience is also negatively affected with DVSA’s method; Haulage operators who might otherwise move their ATF business to a better service offering, may not be able to, because its fleet size might mean there’s not enough volume to re-allocate a DVSA tester from one ATF to another to facilitate the move.
Of course you can argue, why all the talk about competition and speculation, as ATF’s are just testing vehicles, well, there should at least be some weight given to this argument because DVSA elected to partner with commercial enterprise where competition and service delivery balances the equation:
customer choice + service delivery satisfaction =  success
DVSA’s method appears to treat the customer as their commodity, where ATF’s have to ask permission to move them, this can’t be right. If that’s not the case then perhaps DVSA are using their ‘productivity’ method to preserve their supply lines because they don’t do flexible in the way free enterprise can. Either way it feels a bit arrogant and re-opens the conversation to privatise the industry.

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