Is it still legal for an operator to run unregistered services as long as they're free?

Maybe GNE could extract some good publicity and even some onward paying custom by quickly training up a few new drivers and sticking them on low paid temporary contracts driving whatever is lying spare around the group to provide "necessary essential services" to the students/elderly/sick/poor that have been left "stranded" by the striking Stagecoach drivers.

It wouldn't even be too hard to argue to coroporate, if you factored in things like asset usage, training and marketing value, the exercise wouldn't even cost that much, even if it went on for months. Mere pennies on the bottom line of a large group like GNE.

In the old days the might have simply led to an act of solidarity from GNE staff making it unworkable at best, a PR disaster at worst, but these days, when by now I think surely everyone has realised that a newly created Sunderland Municipal Transport is at least five if not ten years away, I'm not so sure it's not at least an even money bet that GNE staff would see this as a sensible act of competition, taking advantage of a temporary weakness in their neighbour's position, that could lead to temporary or even permanent benefits to their own situation.

It would surely be the height of irony if a Stagecoach operation ended up falling victim to the free bus loophole.