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MOT Testing Exemptions Consultation VERY IMPORTANT


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Time for John Attlee, Viscount Prestwood, Antar Owner, Scammell Contractor owner and Conservative spokesperson for Transport in the House of Lords???

 

Tel: 020 7219 6071

Fax: 020 7219 5979

 

The Earl Attlee

House of Lords

London

SW1A 0PW

 

 

attleej@parliament.uk

 

I have e-mailed John, I await his response. We have a reasonable time scale to write to VOSA, so I am going to really think about what to say rather than just banging out an e-mail. I hope to get something away by next weekend.

Edited by antarmike
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I would hardly say its the death knell of our hobby, i see no problem with vehicle safety.

 

The consultation is mainly focused on "Commercial" operators, and all references to the types of vehicles they are proposing to look at is with Commercial operators in mind.

 

I certainly agree that there should be consultation with the Federation of Historic Vehicles etc, there is no representation at all for "Private" owners operating old vehicles for no recompense.

 

Maybe they should consider a Pre (Year) Weight ( x tons) Historic for no monetary gain class.

 

That should sort out all the different silly classes that your vehicle may fall under.

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I would hardly say its the death knell of our hobby, i see no problem with vehicle safety.

 

The consultation is mainly focused on "Commercial" operators, and all references to the types of vehicles they are proposing to look at is with Commercial operators in mind.

 

I certainly agree that there should be consultation with the Federation of Historic Vehicles etc, there is no representation at all for "Private" owners operating old vehicles for no recompense.

 

Maybe they should consider a Pre (Year) Weight ( x tons) Historic for no monetary gain class.

 

That should sort out all the different silly classes that your vehicle may fall under.

 

Removing STGO exemption will mean Antar, Contractor, Rotinoff will all need testing. It will cost me £200 in fuel just to get to my nearest testing station. Currently I can think of several people who take Rotinoffs to rallies on Low loader. Since Road Traffic Act now applies on rally fields these people will need to MOT them just to take it on a low loader to a private field for a bit of a run around.

 

I currently spent £1200 per year on fuel alone for the Antar, now I will have to pay at least another £350 on top of this.

 

Pre 1960 used unladen exemption applies still, but you can't tow a laden trailer. Currently people tow living accomodation (a laden trailer) to rallies behind Explorers, Pioneers, Matadors Diamond T's, and countless other vehicles that Construction and use regs view as Motor tractors, light Locomotives and heavy locomotives. and this is lawful, but now all these vehicles will need testing.

 

Any vehicle that tows a living van or living accomodation on a trailer, will as I understand it need to be tested. I can no longer think of a possible arguement for using any untested vehicle as a towing vehicle for a living van.

 

Some people have there vehicles viewed as "Mobile Project Vehicles" These will also become candidates for testing.

 

Others with Explorers, Leyland Martians, Mk3 Lilitants currently no not require testing if viewed as recovery vehicles, these will all need testing.

 

Engineering plant also comes under testing so Centurion ARV, Conqueror ARV will need testing if viewed by law as engineering plant, (by virtue of fixed winches. They will certainly require testing if viewed as recovery vehicles.)

 

There is talk of a variety of tracked vehicles becoming MOT testable.

 

Remember some people have 3 or 4 vehicles and take each one to only one or two shows. It is perfectly concievable all will need testing, so potentially they may be looking at around £600 in MOT Fees, never mind the fuel to get there.

 

And it will not affect vehicle safety. We all know that there are thosands of cars, vans and HGV's that got a MOT and within a few days, weeks or months, something broke , went out of adjustment or stopped working, and the vehicle continues to be used up until the next MOT without the problem being sorted.

 

If the vehicle was not safe before testing, and has been used for years like that, yes maybe an MOT will sort it out on the day, but if someone was prepared to run in a dangerous condition before, I guess that will have little interst in sorting problem that occur shortly after testing, until they have to for the next MOT.

 

An MOT is not a guarantee that a vehicle is safe. It only says that as far as the examiner was aware it was safe on one particular day, and we all know that testers do miss serious faults under the present testing regime.

 

Remember that if your vehicle is affected and becomes mandatory for testing, and you decide you can't justify the cost, so you intend to sell, the chances are no one else will want to but your vehicle off you if they have to start testing it. Your vehicle currently worth £10,000 as it stands not needing testing will be worth a couple of hundred pounds in scrap.

 

For most of these vehicles there is no emmisions data, and God knows if these vehicles will ever satify VOSA in this respect. This single fact could be the one that wipes out just about all the old Military machinery in a stroke.

 

NO these proposals are deeply damaging and could well be the daeth knell of the movement.

 

Steam rallies, Vintage vehicle shows etc need public coming through the gate to survive. The public come to see a variety, including the big, the heavy, the unusual. If these stop attending because their owners cannot justify the expense of the MOT, then maybe the shows will fold, and the lucky few who own Jeeps, Landy's etc that allways have and always will require testing will find themselves without a worthwhile show to go to. (remebmber these rules have just wiped out as viable, a whole load of Ballast box Scammell Higwaymen and their ilk, that bring showman's living vans to these shows.) What will be left at the shows for the public to look at?

 

This is serious. Get motivated. It doesn't matter who the new sceme is aimed at, what matters is as drafted, who will actually be affected, and the answer to that one is "most everybody" who has a large vehicle.

Edited by antarmike
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I dont think any of us have a problem with being safe. The danger is assuming that DoT does not intend to inflict unnecessary burdens on private owners. It is probable that there is not a hidden agenda. But beware the DoT in the proposal has set some ground work to justify itself on safety grounds, using data they have created from nowhere! they will use this to appeal to those that take it at face value on purely emmotive grounds,..."we are saving lives"!!!

 

But if these recommendations go through whithout accomodation for private owners, we will be subject to requirements that have been brought in over the years and have been applied retrospectively no matter the age of vehicle. Such as side and underrun protection, tachograph, marker lights etc. it goes on and will include the testing itself and the heavy handed actions taken for the slightest problem!

Not a problem for smaller vehicles but a heavy and unnecessary cost to owners of large vehicles.

I am hopefull that with representation we can be accommodated, perhaps with an annual check at an approved place. VOSA stations can be distant and these and the up and coming approved testers will be equipped to test vehicles to modern standards with no facility to assess older vehicles ie. brakes.

Regards

Edited by Mk3iain
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Reading the proposal, i cant see the STGO exemption been removed, and tracked vehicles are still exempt under what they are proposing. I didnt think that living vans were considered "Laden" i thought they had a seperate definition, i thought that laden would mean for example our purposes, a trailer with another vehicle on the back going to a show.

 

My problem with the consultation is they are presuming everybody with a truck or something heavy or different must be a commercial operator, and are going to be setting testing and testing fees with that solely in mind. As far as i can see it isnt proposing to change the vehicle construction rules.

 

I do worry about the type of person that has no HGV driving training, and see the present MOT exemption classes as a way not to bother properly maintaining a vehicle, and jump into potentially a very big rig with unladen trailer and head out onto the Queens highway, my wife and kids could be sharing the same piece of road.

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Reading the proposal, i cant see the STGO exemption been removed, and tracked vehicles are still exempt under what they are proposing.

 

1.5 There are two further categories of effectively exempt ‘heavy vehicles’ that we are seeking to modify in the context of this review:

heavy vehicles which benefit from paragraph 44.1.(e) of the Regulations, which exempts from roadworthiness testing vehicles being used under a specific order made under the Road Traffic Act 1988, or under the provision of the Road Vehicles (Authorisation of Special Types) Order 2003. We are proposing to remove exemptions for HGV or HGV-derived vehicles, while leaving in place exemptions for vehicles of genuinely special type.

 

Make of that what you will.

 

The Contractor is a prime contender for being concidered an HGV, The Antar was offered as a flat bed, oilfield load carrier...

 

Until we know what will be concidered HGV based, and what will be concidered a "genuinely special type" I believe that a ban on most STGO vehicles is possible, particularly if the bill is drafted as badly as some recent legislation.

 

I may be wrong about trcklayers, I thought I saw something which had implications for them, I may be wrong.

 

RE Living vans, in the Military vehicle world a popular choice is the Map Van, Binned stores van of the Brockhouse type. Built for the carraige of goods a n converted by the new owner, fitting sinks, toilet, beds, cupboards for anything and everything.

 

I see every possibility of these being regarded as laden trailers, therefore they cannot be pulled by a pre 1960 vehicle, that is claiming exemtion.

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Reading the proposal, i cant see the STGO exemption been removed, and tracked vehicles are still exempt under what they are proposing. I didnt think that living vans were considered "Laden" i thought they had a seperate definition, i thought that laden would mean for example our purposes, a trailer with another vehicle on the back going to a show.

 

My problem with the consultation is they are presuming everybody with a truck or something heavy or different must be a commercial operator, and are going to be setting testing and testing fees with that solely in mind. As far as i can see it isnt proposing to change the vehicle construction rules.

 

I do worry about the type of person that has no HGV driving training, and see the present MOT exemption classes as a way not to bother properly maintaining a vehicle, and jump into potentially a very big rig with unladen trailer and head out onto the Queens highway, my wife and kids could be sharing the same piece of road.

 

Unfortunately the person that worries you most will be driving a pre 1960 vehicle that it seems will still be exempt. I do not know anyone that fits your description ie with a bad attitude and poorly maintained vehicle, but I am not in the mainsteem up in Aberdeenshire! I am sure others will know if there are any.

I do understand where your coming from though.

Regards

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Unfortunately the person that worries you most will be driving a pre 1960 vehicle that it seems will still be exempt. I do not know anyone that fits your description ie with a bad attitude and poorly maintained vehicle, but I am not in the mainsteem up in Aberdeenshire! I am sure others will know if there are any.

I do understand where your coming from though.

Regards

A lot of the Military vehicles that turn up as shows as STGO units are post 1960, and there will be no exemption for them, if they are deemed to be based on an HGV chassis.

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For those of us that aren't particuarly good at this serious writing thing, would anyone with a better grasp of the English language (and the situation!) care to write a "standard" letter that us oiks could print and sign? I know it's not as good as an individual letter, but probably better than some badly written tosh and certainly better than nothing.

 

I'd very much like to contribute to this, but don't really know enough about the situation in sufficiently technical terms (see my previous posts in this thread...) being new to the MV world to write a valid letter, and I'm sure I'm not the only one.

 

Ta!

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so I am going to really think about what to say rather than just banging out an e-mail. I hope to get something away by next weekend.

 

when you do mike, please dont go on about retro fitting ABS and airbags and dont even go there about the deck chair :pfrt:

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For those of us that aren't particuarly good at this serious writing thing, would anyone with a better grasp of the English language (and the situation!) care to write a "standard" letter that us oiks could print and sign? I know it's not as good as an individual letter, but probably better than some badly written tosh and certainly better than nothing.

 

I'd very much like to contribute to this, but don't really know enough about the situation in sufficiently technical terms (see my previous posts in this thread...) being new to the MV world to write a valid letter, and I'm sure I'm not the only one.

 

Ta!

Good idea, afraid the qualifications count me out though.

A guide may be an idea as government agencys look out for standard letters and if it looks personally written it may bare more weight? maybe. If you try to e-mail your MP it filters out cut and pasted items!

Regards

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when you do mike, please dont go on about retro fitting ABS and airbags and dont even go there about the deck chair :pfrt:

I like a good wind up, and I know the time and place for a wind up, and the time and place to be serious.

 

I won't mention deck chairs....

 

I also won't say that when I brought the Air Portable five Ton" Eager Beaver" trailer back from Yorkshire a couple of week-ends ago, after the first two miles I was so unhappy with the way it was towing, that I rigged breakaway chains to it in a layby, and came the next 100 miles with chains!

 

A wind up is a wind up after all

Edited by antarmike
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Is this in danger of getting a little out of perspective?

 

Just looking at the attached list of currently exempt Vehicle Types as published in the consultation document (the ones they propose to remove are shown in bold print) - where is the cassification under which the vast majority of post 1960 / pre 1973 military vehicles fall (those taxed as Historic Vehicle and which do not carry a load or tow a loaded trailer)? I'm thinking Beford MK, Reo M35, etc.

 

I was of the view that any large vehicle between 1960 and 1973 can run under Historic Vehicle designation, yet requires some form of MOT. MOT exemption has only been open to pre 1960 vehicles or certain specific classes of vehicle.

 

But Historic Vehicle taxation does not permit you to carry a load or tow a loaded trailer.

 

By taxing a vehicle under some other class e.g. Heavy Locomotive you can use the vehicle loaded (i.e. pulling a loaded trailer) without the need for an MOT.

 

So as far as I can see the only impact on the MV scene will be a requirement for post 1960 / pre 1973 vehicles carrying or towing loads (sometimnes very large loads) to have some form of MOT.

 

Can we have some input from some other owners of post 1960 / pre 1973 mvs as to how this proposal might affect them?

 

Would this proposal have an effect on any vehicle other than those used to pull trailers with loads (e.g. tank or other tracked vehicle, second wheeled military vehicle) or towing multiple trailers?

 

We would need to persuade the authorities that it is unreasonable to impose a test rquirement on a historic vehicle which might be used to the limits of its designed carrying/towing capacity on the public highway, albeit only a few times a year.

 

Hmm, I hope Viscount Attlee enjoys a challenge!

 

I think the greater concern to us would be possible imposition of much more stringent MOT conditions for those vehicles which do not have type approval (e.g. imposing current brake performance criteria on old vehicles which could only achieve this by heavy modification).

 

Please don't read into the above that I have a firm view one way or another on this - but we do need to understand where the enemy is coming from in order to stand any chance of persuading him to tactically withdraw :-D

 

 

Annex A

 

 

 

 

List of exemptions from roadworthiness testing in Schedule 2 of the Goods Vehicles (Plating and Testing) Regulations 1988

 

Vehicle type

 

Remove exemption (shown in bold)

 

1. Dual-purpose vehicles.

 

2. Mobile cranes.

 

3. Break-down vehicles.

 

4. Engineering plant etc.

 

5. Tarmac Trailers.

 

6. Tower wagons.

 

7. Road Construction vehicles.

 

8. Fire fighting vehicles.

 

9. Works trucks etc.

 

10. Electrically propelled motor vehicles.

 

11. Snow ploughs etc.

 

12. Lifeboat tractors.

 

13. Living vans*

 

14. Medical /educational/display vehicles.

 

15. Over-run-braked trailers.

 

16. Limited use vehicles.

 

17 Agricultural motor vehicles and trailed appliances.

 

18. Agricultural trailers and agricultural trailed appliance conveyors.

 

18A. Converter dollies.

 

19. Public Service Vehicles*

 

20. Licensed taxis*

 

21. Vehicles used solely for the purposes of funerals*

 

22. HGVs for export and visiting forces vehicles.

 

23. Test HGVs.

 

24. Visiting HGVs*

 

25. Northern Ireland registered HGVs*

 

26. HGVs based in seven Scottish islands.

 

27. Visiting HGV trailers*

 

28. ‘Caterpillar-track’ vehicles.

 

29. Steam propelled vehicles.

 

30. Pre-1960 HGVs.

 

31. Specialised narrow-track utility vehicles.

 

32. Airport ‘handling’ vehicles.

 

33. Airport ‘service’ vehicles.

 

34. Police HGVs.

 

35. HGV tractor units drawing exempt trailers.

 

36. Play buses*

 

37. Large American pick-up trucks*

 

* vehicles marked with an asterisk , while exempt from testing of HGVs under the Goods Vehicles (Plating and Testing) Regulations 1988, are nevertheless subject to roadworthiness testing under the separate testing regimes applied to cars (MOT), passenger service vehicles, or under legislation in Northern Ireland or their home state.

Edited by N.O.S.
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I also think it would help greatly if the authorities can be persuaded to define HGV-based vehicles as being those constructed to "current HGV performance standards" (i.e. modern vehicles, which I'm sure is what they intend this to cover) and therefore easily MOTable, and to consider suitable exemption or simplified 'condition testing' for those older vehicles which are not so constructed (which I think they have made reference to in the document for things like tracklayers).

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this is the problem lack of definition on what they are proposing post 1960 ferret is classed as a motor tractor, motor tractor is the way i read it one of the exemptions going ,but of course it is not hgv based so does it get re-classed as a 1960 1973 historic vehicle does it now have to be tested ,is it class 4 mot or 7?

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this is the problem lack of definition on what they are proposing post 1960 ferret is classed as a motor tractor, motor tractor is the way i read it one of the exemptions going ,but of course it is not hgv based so does it get re-classed as a 1960 1973 historic vehicle does it now have to be tested ,is it class 4 mot or 7?

 

I would imagine a ferret would be a Heavy Motor Car taxed as Historic, why would a post '60 ferret be exempt?

 

I am still pondering the consultation, will come up with a comment in due course

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vosa at the moment regard 1964 ferret as a motor tractor there fore mot exempt, have letter dated end of dec2009 that states as much, that aforementioned letter also mentions this consultation that is going on at the moment, hence me starting this thread. paul.:cool2:

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Spoke to MVT chairman today, they had heard on Friday and are looking into it, also wrote to my MP. I think we can see that the bill as proposed is pretty much a done deal, it is going to happen. What we can do is look for a bit of fine tuning.

I have a M1008 ( no problem there, it is tested like any other car of its age!) and an AEC Mk3 recovery. I cannot find any excuse for my own vehicle not having an annual test of some sort.

 

I am not qualified to speak for the many other classes of vehicle out there.

 

I think we should try to be positive and put forward options that would be acceptable to all.

Ie. Perhaps if post 1960 pre 1973 vehicles could be annually checked/tested at approved places such as LGV operators and garages that are allready approved to carry out safety checks.

The checks should be sympathetic to age and use, such as "historic" and the rules that allready apply to this classification. They could be local and at reasonable cost.

Maybe its not that simple for all.

Regards

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A lot of people own quite modern trucks (myself included) which are not classified as "Historic" due to being under 25 years of age. I would need to wait until 2011 to clasify mine as "Historic". Also we have got a lot more complicated problems due to age, I.E. Under run and side impact equipment which changes the look of the vehicle, marker lights that were not fitted equipment from new would then need to be added, exhaust emissions and brake regulations etc.

 

If this is going to come in without amendment then this legislation has a good chance of rendering these vehicles useless.

 

We need to make sure we still send out the emails and letters. I find it very worrying that not even IMPS or the MVT had heard anything about this, even though they are recognised by the DVLA as having Vehicle Verification Officers that inspect and forward reports on the very vehicles they are looking at to DVLA for registration.

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Is this in danger of getting a little out of perspective?

 

Just looking at the attached list of currently exempt Vehicle Types as published in the consultation document (the ones they propose to remove are shown in bold print) - where is the cassification under which the vast majority of post 1960 / pre 1973 military vehicles fall (those taxed as Historic Vehicle and which do not carry a load or tow a loaded trailer)? I'm thinking Beford MK, Reo M35, etc.

 

I was of the view that any large vehicle between 1960 and 1973 can run under Historic Vehicle designation, yet requires some form of MOT. MOT exemption has only been open to pre 1960 vehicles or certain specific classes of vehicle.

 

But Historic Vehicle taxation does not permit you to carry a load or tow a loaded trailer.

 

By taxing a vehicle under some other class e.g. Heavy Locomotive you can use the vehicle loaded (i.e. pulling a loaded trailer) without the need for an MOT.

 

So as far as I can see the only impact on the MV scene will be a requirement for post 1960 / pre 1973 vehicles carrying or towing loads (sometimnes very large loads) to have some form of MOT.

 

Can we have some input from some other owners of post 1960 / pre 1973 mvs as to how this proposal might affect them?

 

Would this proposal have an effect on any vehicle other than those used to pull trailers with loads (e.g. tank or other tracked vehicle, second wheeled military vehicle) or towing multiple trailers?

 

We would need to persuade the authorities that it is unreasonable to impose a test rquirement on a historic vehicle which might be used to the limits of its designed carrying/towing capacity on the public highway, albeit only a few times a year.

 

Hmm, I hope Viscount Attlee enjoys a challenge!

 

I think the greater concern to us would be possible imposition of much more stringent MOT conditions for those vehicles which do not have type approval (e.g. imposing current brake performance criteria on old vehicles which could only achieve this by heavy modification).

 

Please don't read into the above that I have a firm view one way or another on this - but we do need to understand where the enemy is coming from in order to stand any chance of persuading him to tactically withdraw :-D

 

 

Annex A

 

 

 

 

List of exemptions from roadworthiness testing in Schedule 2 of the Goods Vehicles (Plating and Testing) Regulations 1988

 

Vehicle type

 

Remove exemption (shown in bold)

 

1. Dual-purpose vehicles.

 

2. Mobile cranes.

 

3. Break-down vehicles.

 

4. Engineering plant etc.

 

5. Tarmac Trailers.

 

6. Tower wagons.

 

7. Road Construction vehicles.

 

8. Fire fighting vehicles.

 

9. Works trucks etc.

 

10. Electrically propelled motor vehicles.

 

11. Snow ploughs etc.

 

12. Lifeboat tractors.

 

13. Living vans*

 

14. Medical /educational/display vehicles.

 

15. Over-run-braked trailers.

 

16. Limited use vehicles.

 

17 Agricultural motor vehicles and trailed appliances.

 

18. Agricultural trailers and agricultural trailed appliance conveyors.

 

18A. Converter dollies.

 

19. Public Service Vehicles*

 

20. Licensed taxis*

 

21. Vehicles used solely for the purposes of funerals*

 

22. HGVs for export and visiting forces vehicles.

 

23. Test HGVs.

 

24. Visiting HGVs*

 

25. Northern Ireland registered HGVs*

 

26. HGVs based in seven Scottish islands.

 

27. Visiting HGV trailers*

 

28. ‘Caterpillar-track’ vehicles.

 

29. Steam propelled vehicles.

 

30. Pre-1960 HGVs.

 

31. Specialised narrow-track utility vehicles.

 

32. Airport ‘handling’ vehicles.

 

33. Airport ‘service’ vehicles.

 

34. Police HGVs.

 

35. HGV tractor units drawing exempt trailers.

 

36. Play buses*

 

37. Large American pick-up trucks*

 

* vehicles marked with an asterisk , while exempt from testing of HGVs under the Goods Vehicles (Plating and Testing) Regulations 1988, are nevertheless subject to roadworthiness testing under the separate testing regimes applied to cars (MOT), passenger service vehicles, or under legislation in Northern Ireland or their home state.

Iam sorry to say that your post is really quite flawed, I won't pick up on everything that I believe you have got wrong, I am trying to keep a united front on this one.

 

Any historic vehicle of any age can carry a load, proovided it isn't in connection with a business.

 

You seem to be getting confused with driver licencing rules that say you can drive a pre 1960 vehicle unladed without an HGV licence, but this also means that you can drive it laden provided you have the correct HGV licence. You can also pull a laden trailer with a pre 1960 vehicle providing it is tested, if necessary, and the load . again , is not in connection with a business.

 

Motor tractor, Light Locomotive and hevay locomotives are not taxation classes. These are vehicle definitions outlined in Construction and use regs. Currently all these classes are MOT exempt.

 

In this class are any vehicle that is not designed to carry a load, itself. All manner of ballast tractors post 1960 but pre 1973have been exempt, but will now require testing. Can you indicate if you think you vehicle falls in this category, because it is proposed you need to tbe tested. All Pre 1960 Motor tractors Light and heavy locomotives, have also been exempt but will also need testing.

 

Anyone with a recovery vehicle of whatever age will be required to MOT it, be it Wartime Mack, Ward LeFrance, Pioneer, or post war Explorer, militant, Foden Eka Scammell, Martian. That is quite a lot of vehicles requiring testing amongst the members of this forum!

 

Taxation class is not the same as vehicle definition. All Motor tractors, light locomaotives, and heavy loco's built before 1973 will require testing even if they are taxed Historic.

Edited by antarmike
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