latest dvla problem

[xtreme]

In previous posts I explained I was trying to register a cvrt stormer thats within width this is the dvla's latest response

 

 

Dear Sir,

 

Further to our telephone conversation yesterday I have been informed by DfT that the Ministry of Defence have advised that the vehicle in question does not meet the full requirements of the Construction and Use Regulations 1986 and the Road Vehicles Lighting Regulations 1989 and these vehicle were never intended for on road use.

 

Whilst DfT are unable to provide a full and detailed breakdown of exactly which areas the vehicle does not comply with the Construction and Use Regulations, I have been advised that these vehicles do not meet the full requirements of Regulations 15 & 16 of the Construction and Use Regulations with regard to braking system requirements, secondary braking requirements and having two independent means of braking.

 

If you require more detailed information of how the vehicle does not comply with the Construction and Use requirements, I can only suggest that you contact the manufacturer for further information.

 

I hope this is helpful.

 

Regards

[antarmike]

sorry, but that seems fairly straightforward. If the vehicle does not fully comply with C and U regs and lighting regs, then it should not be registered..

 

Do you feel that it does fully comply? How has the vehicle been modified to provide two separate braking systems? Because if no mods have been done, then presumably the Army's description of the braking circuits is accurate and DVLA are only applying the rules they have to work by.

 

The Army says it does not comply with lighting regs. How has the vehicle been modified to ensure that it now complies. If no mods have been carried out, then presumably DVLA are again right to apply the rules they have to work by. They should not be registering non compliant vehicles.

[Richard Farrant]

sorry, but that seems fairly straightforward. If the vehicle does not fully comply with C and U regs and lighting regs, then it should not be registered..

 

Do you feel that it does fully comply, How has the vehicle been modified to provide two separate braking systems, because if no mods have been done, then presumably the Army's description of the braking circuits is accurate and DVLA are only applying the rules they have to work by.

 

The Army says it does not comply with lighting regs. How has the vehicle been modified to ensure that it now complies. If no mods have been carried out, then presumably DVLA are agin right to apply the rules they have to work by. They should not be registering non compliant vehicles.

 

As the vehicle in question is a CVR(T), then it does have separate braking systems, hyd main brake, hand operated parking brake and steering brakes on separate system. No modifications this is how they are.

[sirhc]

It sounds like they may have confused the Stormer with a 432? 432 does not have seperate steering and braking systems, whereas Stormer and CVRT series vehicles do. I would also be interested to know how it doesn't confom with regards to lighting, since it has everything except fog lights. Maybe it's to do with the height or spacing of headlamps?

 

(Richard beat me to the first bit!)

[ChasSomT.]

How does the Stormer's braking system differ from the rest of the CVR(T) family?

'Not designed for use on public roads' - Total TWONK !

More ignorant 'Government' rubbish.

I think it would be found, that one of the design criteria for the CVR(T) family of vehicles, was that it could be used, without any modification, on public roads, in this country, and in mainland Europe. (It is 'Left Hand Drive' isn't it?)

'Grasping at straws, Making it up as they go along' What next, 'The wrong colour'?

At least 'the taxpayer' is getting something back, when the Military disposes of vehicles, do 'They' want to stop that income source?

As ever, no 'Joined-up thinking' from our so called 'Elders and betters' !

Another Quango that missed 'The Axe' !

 

Grr. . . .

[antarmike]

As the vehicle in question is a CVR(T), then it does have separate braking systems, hyd main brake, hand operated parking brake and steering brakes on separate system. No modifications this is how they are.

Reading the initial post, DVLA say the vehicles do not comply with C and U regs. They say Ministry of Defence have not provided information as to why they do not comply, just the fact it does not.. The recommendation was made to contact the manufacturers to find out how and why the vehicles do not comply.

 

There is no definite statement that the description of the braking system came from MOD.

 

If this part of what DVLA told Xtreme is incorrect, that is unimportant. MOD have said vehicle neither complies with C and U nor Lighting regs.

 

They say that Stormer was not designed or intended for road use.

 

Until Xtreme has contacted the manufacturer, or someone goes through C and U and Lighting regs, clause by clause, to ensure vehicle is fully compliant, I think it is reasonable to accept MOD view the vehicle does not comply.

 

MOD will know whether it does or no tit does comply because if it doesn't they will have applied to Secretary of State for exemption from complyiing with C and U and lighting regs, because of operational requirements.

Edited October 19, 2010 by antarmike

[sirhc]

Look at all these Stormers not driving around on roads..........

 

http://www.youtube.com/watch?v=7oRwuJHu79M&feature=related

[xtreme]

Stormer has 2 braking systems same as all the cvrt's . Lights meet C&U except rear fog light which can easily be installed . Lighting regs is a very simply modification . This is just another DVLA dont want to register so wont . I have replied that this is not satisfactory and want to appeal the decision and the vehicle is available any time for dvla and vosa to complete a c&U inspection.

[timbo]

Look at all these Stormers not driving around on roads..........

 

http://www.youtube.com/watch?v=7oRwuJHu79M&feature=related

 

CVRT's, Saxons, Stormers - I just thought this was a vid of Dan's back garden...!

 

Dan - count to 10, keep calm and carefully explain to them that they've got the wrong vehicle, which they clearly have... Good luck..

[xtreme]

Heres the crazy thing lets say when it was manufactured it didnt meet C&U whats to stop you modifying it to meet C&U . There is no such Test C&U DVLA registration has always been a self declaration . Someone dosent want these vehicles registered

[antarmike]

It sounds like they may have confused the Stormer with a 432? 432 does not have seperate steering and braking systems, whereas Stormer and CVRT series vehicles do. I would also be interested to know how it doesn't confom with regards to lighting, since it has everything except fog lights. Maybe it's to do with the height or spacing of headlamps?

 

(Richard beat me to the first bit!)

 

Headlamps cannot be more than 400mm from outside edge of headlamp to extreme of bodywork(any vehicle built after 1972) , I doubt that stormer complies.

 

Do we know date of first use of this Stormer? if first use is before 1st April 1986 or build date is before 1st Oct 1985, front marker lights cannot be more than 510mm from edge of body work, or 400mm if built after 1st Oct 1985.

Edited October 19, 2010 by antarmike

[ferrettkitt]

Headlamps cannot be more than 400mm from outside edge of headlamp to extreme of bodywork(any vehicle built after 1972) , I doubt that stormer complies.

 

Do we know date of first use of this Stormer? if first use is before 1st April 1986 or build date is before 1st Oct 1985, front marker lights cannot be more than 510mm from edge of body work, or 400mm if built after 1st Oct 1985.

 

Surely the positions of the lights can be altered to enable the vehicle to comply. If the DVLA have used the wrong model or vehicle type as there example of why it can't comply that would be the owners perogative to challenge them. Would the freedom of information act enable Dan to find out where the DVLA have got there info from.

[Marmite!!]

I believe Withams recently stated (from an email that was forwarded) that certain vehicles they sell are only sold are only suitable for off road use & they do not recommend them for use on the road.. I think Withams should clearly state this in the terms of sale (Maybe they do?) if this is true?? this would save any confusion when buyers tried to road register them.

[CVRTNick]

I would have thought it is a width issue,the old 1980/70’s) CVRT's were under width & the new ones are over 2.55m wide,the newer they are,the fatter they are.

[antarmike]

Surely the positions of the lights can be altered to enable the vehicle to comply. If the DVLA have used the wrong model or vehicle type as there example of why it can't comply that would be the owners perogative to challenge them. Would the freedom of information act enable Dan to find out where the DVLA have got there info from.

Maybe the lights can be altered, but until they are this is certainly enough reason for DVLA to refuse registration.. Until I know an exact build date and first use date I cannot comment upon what might need changing.

 

It may be that lights will require to be marked with E mark. I do not know whether standard Military lights of the time comply in terms of having an E mark. It might not be just a question of moving lights, but rather of changing lights to ones correctly marked.

[timbo]

I would have thought it is a width issue,the old 1980/70’s) CVRT's were under width & the new ones are over 2.55m wide,the newer they are,the fatter they are.

 

I think one of the frustrations here is the lack of a consistent approach. They could refuse on a number of grounds potentially, width, lighting or braking (although I didn't think width was an issue for Stormer and brakes shouldn't be so that just leaves lights), but they have registered all manner of things in the past (including lots of 432's with linked braking and steering and more than 2.55M wide). I think this may become more of an issue with the number of 432s and other vehicles coming out. It may be that in the past there were too few vehicles being registered for them to worry about but as more vehicles pass into civvy ownership the previously pragmatic approach starts to harden as officialdom takes over..

[xtreme]

Year is 1996 and the width is 2.50M to the millimetre Its nothing to do with the vehicle as he has told me that all tracked MV's were registered incorrectly . so that affects most of Us .

 

Now dont thing that because its registered it dosent affect you because last year there were many stretched limos that had there registrations revoked . All had to be sold abroad.

 

I have a JCB that defo dosent meet c&U yet its registered . As are many tracked plant . My Gut feeling is they have been told not to register MV's do to the current terrorist threats. Current intel is that they are expecting a mombai style attack According the the local Mcr Manpad team.

[TooTallMike]

...they have registered all manner of things in the past (including lots of 432's with linked braking and steering and more than 2.55M wide). I think this may become more of an issue with the number of 432s and other vehicles coming out. It may be that in the past there were too few vehicles being registered for them to worry about but...

More likely in the past people self-declared vehicles such as 432s as compliant for road use but DVLA/VOSA did not check whether this was actually valid. Now they are checking. It does not mean those vehicles were registered legally - the width rule has been in the regulations for a long time.

 

With regard to the MoD letter about C&U - the MoD's perspective is that their vehicles are not specifically designed to meet C&U. In other words MoD simply don't have to concern themselves with whether they are compliant or not. This does not mean that they cannot be modified to meet the regs and once they do it should be possible to register them as the criteria to be met are there in black and white.

 

- MG

[Stormin]

If the Authorities wanted to take Construction and Use regulations to the letter there wouldn't be many vehicles left on the roads. I'm sure even newly registered 60 plate cars will be found to fail on some minor detail.

It seems that with the current mindset of the DVLA it's going to be very difficult to try and get any tracked MV registered for the road now.

Big question is will this extend beyond tracked MV's and will they try and remove previously registered tracked military vehicles from the roads?

[timbo]

My Gut feeling is they have been told not to register MV's do to the current terrorist threats. Current intel is that they are expecting a mombai style attack According the the local Mcr Manpad team.

 

But if they are so worried about this then why are the MOD selling 432s at £3.5K each !!!! Joined up thinking there..!

 

I suspect the truth may be a bit of all of these things.

 

Will be interesting to see if it does get any easier after todays announcements. DFT/DVLA are one of the biggest employers of civil servants and I would imagine are most definitely in the firing line for big cuts in manpower. Course that might just mean the position hardens even more..

[antarmike]

Year is 1996 and the width is 2.50M to the millimetre Its nothing to do with the vehicle as he has told me that all tracked MV's were registered incorrectly . so that affects most of Us .

 

Now dont thing that because its registered it dosent affect you because last year there were many stretched limos that had there registrations revoked . All had to be sold abroad.

 

I have a JCB that defo dosent meet c&U yet its registered . As are many tracked plant . My Gut feeling is they have been told not to register MV's do to the current terrorist threats. Current intel is that they are expecting a mombai style attack According the the local Mcr Manpad team.

 

JCB's and tracked plant will be registered under STGO construction rules and limitations as to use. Privately owned tracked armour cannot generally be run under STGO rules

 

Doubt whether they think the fact that a tracked vehicle can't be registered will prevent a Terrorist atack, Terrorists break every rule!

Edited October 20, 2010 by antarmike

[andym]

My Gut feeling is they have been told not to register MV's do to the current terrorist threats. Current intel is that they are expecting a mombai style attack According the the local Mcr Manpad team.

 

... and of course, terrorists would be careful to ensure that their vehicles were fully road-legal before mounting an attack? :nut:

 

I suggest that the answer is in the statement that "I have been informed by DfT that the Ministry of Defence have advised that the vehicle in question does not meet the full requirements of the Construction and Use Regulations 1986 and the Road Vehicles Lighting Regulations 1989." I'd go back to them and ask to see exactly what that MOD advice was.

 

Andy

[steveo578]

for my 2p worth- the MOD is in effect the previous owner -not the manufacturer -therefore they might as well say they got the opinion from "Steve down the pub"

[Stormin]

... and of course, terrorists would be careful to ensure that their vehicles were fully road-legal before mounting an attack? :nut:

 

I suggest that the answer is in the statement that "I have been informed by DfT that the Ministry of Defence have advised that the vehicle in question does not meet the full requirements of the Construction and Use Regulations 1986 and the Road Vehicles Lighting Regulations 1989." I'd go back to them and ask to see exactly what that MOD advice was.

 

Andy

 

I doubt the MOD made any such comment in the first place. They have no need for any vehicles to comply with construction and use regs as they're all exempt. I wouldn't expect they need any knowledge of how or why they fail to comply. I would expect if any MOD advice was given at all it was a simple off the cuff comment from someone who didn't want to get involved.

If you really want to find out how it doesn't comply with construction and use the only way is to get it into VOSA for an official IVA test. They'll come back with a huge list of sharp edges, mirrors being too stiff, dangerous for pedestrians, not enough padding inside in case of accidents to name a few. The list will be endless.

For the record I would imagine if I ran my 101 in for a similar test the list would be almost as extensive.

[andym]

for my 2p worth- the MOD is in effect the previous owner -not the manufacturer -therefore they might as well say they got the opinion from "Steve down the pub"

 

These vehicles are probably old enough to date back to the days when MOD was the Design Authority, methinks. But as I said above, it would be interesting to know exactly what advice was sought and given.

 

Andy