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MOT Testing Exemptions Consultation VERY IMPORTANT


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As far as I can see the subject of exemption from vehicle testing was brought up several years ago which was probably when this thread was originated. The thread is so long now, I haven't got time to read it all, but the following link has been sent in to the letters page of Windscreen illustrating that the subject is up for consultation again. So we all need to jump on the band wagon and oppose it.

 

All I can say is: f*$@&n Europe!!

 

https://www.gov.uk/government/consultations/hgv-periodic-testing-and-inspections-exemptions

 

Richard

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  • 2 years later...

 

So no change for most of us with 40+ yr=old vehicles.

 

But might affect those who have fitted new modern more powerful engines into 40+ yr-old HGVs, if that means they are "Substantially changed"?

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I thought HGV's and PSV's remained unchanged as requiring an annual MOT in the proposals out today. Only only Vehicles of Historic Interest (cars/motorbikes etc) were to be exempted. And for these engine swaps should not exceed more than a 15% increase in power output over the OE fitment.

 

No, my 1943 CMP C60s weighs more than 3.5T unladen, but will continue to not require an MOT or formal inspection as it is not used commercially. If, say, I installed a large modern powerful diesel engine, then it would. Which does make sense.

Quote from Government response to consultation:

Other Classes of Vehicle26.

The consultation asked if the exemption from testing should also apply to largervehicles such as Heavy Goods Vehicles and Public Service Vehicles. (These vehiclesare currently generally exempt from testing if built before 1960.) 479 respondentssupported this proposal. 754 said that HGVs and PSVs should be tested, while 27 saidthat they should be exempted if they were not used commercially. 251 respondentsreplied ‘No’ because they did not support any exemption for these vehicles. Reasonsgiven for objecting to this proposal included the following:

• ‘The additional size and weight of the vehicles in these classes make testingessential to save lives.’

• ‘PSV and HGV vehicles that are used for business should be tested as it is likelythat their usage will be heavy and up to their original specifications. Privatelyowned vehicles are less likely to operate under those conditions - attendingshows, displays and events on an irregular basis.’10

• ‘These vehicles may carry multiple passengers and if involved in a collision willresult in a greater number of injuries.’

 

We have decided not to amend the existing position of old heavy goods vehicles(more than 3.5 tonnes unladen weight) and public service vehicles (with 12 seatsor more) in respect of testing, with one exception – pre-1960 buses and HGVswhich have been changed substantially will need to be tested.

We accept thatthere is concern over the implications of accidents involving heavier vehicles and thosecarrying groups of passengers, in some cases commercially. It is also appropriate thatlarge vehicles are subject to the same level of operator licensing requirementsregardless of the vehicle age.

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If they do adopt the 8-point system, an engine change is only one point lost. As far as I understand it, that means no change to the vehicle's test-exempt status.

 

That is if they use the 8-point system.

 

In a more general sense I don't understand why 'they' think modified vehicles of a certain age should be subjected to testing and yet not un-modified ones? If anything, one might suggest that someone who owns a modified vehicle may have a more than usual interest in its engineering and thus may well be maintaining it to a better level than someone who has simply bought something and runs it with little interest in what goes on underneath.

 

- MG

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If they do adopt the 8-point system, an engine change is only one point lost. As far as I understand it, that means no change to the vehicle's test-exempt status.

 

That is if they use the 8-point system.

 

In a more general sense I don't understand why 'they' think modified vehicles of a certain age should be subjected to testing and yet not un-modified ones? If anything, one might suggest that someone who owns a modified vehicle may have a more than usual interest in its engineering and thus may well be maintaining it to a better level than someone who has simply bought something and runs it with little interest in what goes on underneath.

 

- MG

 

Engine changes will be allowed under 8 points, unless the power to weight ratio increases by more that 15%..

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So the pre-1960 MoT exemption remains for HGV's/PSV's provided they are not significantly modified but those post 1-1-1960 will still require an MoT. For the pre-1960 one then - how will that affect older ladies like Scammells and Ward La Frances etc where the original petrol engines are replaced by more powerful diesels? For cars one of the stipulations was not more than a 15% power increase over OEM - are the engine upgrades on these older ladies more than 15%??

 

No, my 1943 CMP C60s weighs more than 3.5T unladen, but will continue to not require an MOT or formal inspection as it is not used commercially. If, say, I installed a large modern powerful diesel engine, then it would. Which does make sense.

Quote from Government response to consultation:

Other Classes of Vehicle26.

The consultation asked if the exemption from testing should also apply to largervehicles such as Heavy Goods Vehicles and Public Service Vehicles. (These vehiclesare currently generally exempt from testing if built before 1960.) 479 respondentssupported this proposal. 754 said that HGVs and PSVs should be tested, while 27 saidthat they should be exempted if they were not used commercially. 251 respondentsreplied ‘No’ because they did not support any exemption for these vehicles. Reasonsgiven for objecting to this proposal included the following:

• ‘The additional size and weight of the vehicles in these classes make testingessential to save lives.’

• ‘PSV and HGV vehicles that are used for business should be tested as it is likelythat their usage will be heavy and up to their original specifications. Privatelyowned vehicles are less likely to operate under those conditions - attendingshows, displays and events on an irregular basis.’10

• ‘These vehicles may carry multiple passengers and if involved in a collision willresult in a greater number of injuries.’

 

We have decided not to amend the existing position of old heavy goods vehicles(more than 3.5 tonnes unladen weight) and public service vehicles (with 12 seatsor more) in respect of testing, with one exception – pre-1960 buses and HGVswhich have been changed substantially will need to be tested.

We accept thatthere is concern over the implications of accidents involving heavier vehicles and thosecarrying groups of passengers, in some cases commercially. It is also appropriate thatlarge vehicles are subject to the same level of operator licensing requirementsregardless of the vehicle age.

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Engine changes will be allowed under 8 points, unless the power to weight ratio increases by more that 15%..

...under which circumstances how many points is it then?

Edit: answered my own question - points are irrelevant if over 15% increase means it us substantially altered.

 

If a hypothetical truck with a 'radically altered' engine became testable, would it mean it could then carry load and tow a laden trailer?

 

MG

 

MG

Edited by TooTallMike
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True to type - 'authenticity' to retain historic status.

 

Under the 8 point system for historic status , as it stands presently (but seems there is to be a change) - if you retain a original spec. engine then you gain 1 point , therefore if you can tot up 8 points without the engine 1 point ,then you can bolt whatever you wish within the engine bay and remain of historic interest vehicle status. However this can't work with the new proposals because you are not Criterion 1 or Criterian 2 (not a vehicle of historic interest in any case).

 

Quite simply if you are not meeting Criterian 1 - then this is applicable :-

 

Read the para. of the Draft Guidance headed - The criteria for substantial change - plain English self explanatory.

 

-------------

 

Clearly the Regulation / Rules for the 8 points concerning engine will have to be re-written to make sense. This they confirm - read the sentence about - intended alterations to be made to the processes..

Edited by ruxy
spelin
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Not all of this is set in stone yet, there is an email address in there for anyone to voice their opinion before it's too late.

 

The suggestions made by those who filled in the questionnaire have clearly influenced some of the decisions made, but

as only 2000 people out of probably 20,000 affected people bothered to fill in the questionnaire, I doubt many will bother to email in their concerns either.

 

The 15% idea is particularly ridiculous with regard to historic HGVs, heavy locomotives have never had to be tested even before the pre 60 exemption came about.

 

What about the Scammell 100 tonner? it had a huge increase in power a couple of years after it was made.

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...The 15% idea is particularly ridiculous with regard to historic HGVs, heavy locomotives have never had to be tested even before the pre 60 exemption came about....

Not just heavy locomotives but also recovery vehicles. Are they to be included in this?

 

If a vehicle ceases to be a VHI by virtue of being substantially modified, it has to fit into one of the other existing vehicle classes. That class is not recorded on the V5 so how does one go about claiming it? If you tick 'yes' on a form that asks whether the vehicle has been substantially modified they will ask for proof of MoT. How do you then state it is in an exempt class?

 

- MG

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A significant and relevant benefit of extra horses is the improved performance which goes a long way to help with keeping up with traffic - not top speed but acceleration to help traffic flow.

Not to mention the reduction in emissions between a petrol engine doing 1mpg and a diesel doing 13mpg!

 

- MG

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Not just heavy locomotives but also recovery vehicles. Are they to be included in this?

 

If a vehicle ceases to be a VHI by virtue of being substantially modified, it has to fit into one of the other existing vehicle classes. That class is not recorded on the V5 so how does one go about claiming it? If you tick 'yes' on a form that asks whether the vehicle has been substantially modified they will ask for proof of MoT. How do you then state it is in an exempt class?

 

- MG

Looks like breakdown vehicle is to cease being a test exempt class as of May 2018.

 

Not found any mention of heavy locomotives.

 

- MG

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Since the Historic tax MOT exempt thing first came about we all knew that a Series One LR body on a shortened RR chassis, a monster V8, Unimog portal axles not needing an MOT and getting free tax was not playing the game, unfair and just wrong. Even if some of us took advantage!

 

Seems to me that what's being done here is to enforce the regulations that have been in place for many years but largely ignored by most vehicle tinkerers/modifiers, and to clear up the definition of a Vehicle of Historic Interest to reflect the original lawmakers intentions.

 

A vehicle has to be completely stock (14 points), stay within the 8 point rule, or if modified outside that or home built go for a BIVA test.

 

The important difference is that it will be up the the vehicle keeper to declare modifications when taxing or face tax fraud charges and all that entails.

 

The 8 point rule still allows plenty of room for changing things if you feel you need to, but the 15% power to weight increase seems to be completely unexpected and a hard thing to comply with as we know large numbers have engine conversions that are in themselves a part of the vehicles ancient history.

 

There is still time to lobby and let them know your angle, as they do seem to have taken peoples views into consideration, and presumably will still do so.

 

Or run for the hills! :shake:

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I am in the process of composing my email response to the proposals and would urge others to do the same.

 

I do not see how the 15% increase in power/weight ratio can be enforced as it is almost impossible to calculate. There is no way of knowing the true hp output of any engine without a dyno test. Even from the factory an engine is unlikely to equal the manufacturer’s stated power output. Once it has been used/rebuilt/modified the output is anyone’s guess.

 

To take an example, the Cummins ‘B’ series range of 6-cylinder 12-valve diesel engines built from 1984-1998 has versions starting at 110hp going up to 1000+hp in custom applications. There are literally thousands of combinations of injection pumps, injectors, turbos and other internal and external components that all have a different effect on the power output. It would take an astoundingly skilled expert to accurately calculate this output on paper, and even then this would likely have to be confirmed by a dyno test. Therefore it is not reasonable or practicable to expect every owner to be able to correctly declare whether their vehicle falls above or below the +15% threshold.

 

The 8-point system seems more than adequate to cover the extent of vehicle modifications given the small numbers of vehicles likely to be affected.

 

- MG

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I've been trawling the net for 3 hours now trying to find any factual reference to the 15% power/weight ratio increase voiding the 8-point registration system but I can only find anecdotal evidence. Could someone please direct me to the primary legislation or guidance notes that covers this?

 

- MG

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There ya go Mike

 

Criterion 1

If a vehicle has a power to weight ratio of more than 15% in excess of its originaldesign, unless such a modification took place before 1988.

 

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/644962/vehicles-of-historical-interest-substantial-change-guidance.pdf

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There ya go Mike

 

Criterion 1

If a vehicle has a power to weight ratio of more than 15% in excess of its originaldesign, unless such a modification took place before 1988.

 

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/644962/vehicles-of-historical-interest-substantial-change-guidance.pdf

I'm sorry, I had read one of your and one of Neil's earlier messages as suggesting that the 15% increase guff was already used by DVLA to assess the status of radically altered vehicles for the purpose of determining whether they should have q plates. I also read this on several other forums but all un-substantiated.

 

Where has this element of the DfT/VOSA proposal come from then?

 

- MG

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From thin air Mike, complete surprise, there was no mention of it at all in the questionnaire.

I have not been able to find any factual mention of it anywhere until this guidance doc. I don't recall any mention of it in the original proposal.

 

The 8-point system has been used by the DVLA since 1988(?) to determine whether a vehicle is merely modified or whether it has been radically altered. Tens of thousands of people across the country have used these guidelines as a basis for changes to their vehicles which were entirely within the law, and yet suddenly the goalposts may be moved and applied retrospectively.

 

This is about modifications to existing engines as well as conversions. Anyone with so much as a weber carb on a L-R 2.25l should be concerned as this will affect you!

- MG

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