important MOT Testing Exemptions Consultation VERY IMPORTANT

[antarmike]

Can I please urge you to re-read this thread, and you will see that the same questions keep coming up, and I believe that they have already been answered.

 

I cannot keep going over old ground to give a response that has already been made several times before.

 

If I am sure that something has been covered I will have to start giveing the good old "prime-minister's question time" response of " I refer you to my previous answer"

 

I do not mean to be rude to anyone, but I am a volunteer and I shouldn't be revisiting the same question time and time again.

 

 

P.S. I have talked to Robert newman and I have an understanding of what is possible, and what is not.

 

Everyone would do well to re-read the consultaion document, and in particular to look at the suggested questions you should be answering as part of the consulation process, you will then see that what some of you are expecting me to say falls well outside what they see the function of the consultation. (Section 5, page 9)

 

Having said that just because I don't think a suggestion has any hope of having an influence, nothing I am doing prevents any individual from making his own representaion, or making his own suggestion as to a way forward.

 

I want to concentrate on what I am lead to believe may be possible in terms of winning concessions, having talked to the man.

 

Off to bed now, see you in the morning, Mike.

Edited February 12, 2010 by antarmike

[antarmike]

Hi Rob , My 1955 Explorer is registered as a BREAKDOWN TRUCK since 1988 and has taxation type HISTORIC and a wheel plan of THREE AXLE RIGID ! I'll be using the pre 1960 route for MOT exemption when I eventually finish restoring her providing the petrol don't run out !:-D

 

It might be registered as a breakdown truck, but it is not a breakdown truck for the reasons I have already stated. Three axle rigid body is completely meaningless in the context of this consulation process, again for reasons I have already stated.

 

Vosa/ DfT will view it as a locomotive.

[AndyFowler]

It might be registered as a breakdown truck, but it is not a breakdown truck for the reasons I have already stated. Three axle rigid body is completely meaningless in the context of this consulation process, again for reasons I have already stated.

 

Vosa/ DfT will view it as a locomotive.

 

So as its pre 1960 its still exempt as I understand it !

[ferretfixer]

The Story so far.

 

 

 

No Forum member has come forward indicating that they consider their vehicle to be Engineering Plant. Likewise unless I hear to the contrary I assume no Forum Member is affected by the proposed removal of MOT exemption for this class.

 

 

 

I welcome helpful comment, but please if you wish to pull this apart or challenge the basic way I am trying to deal with this please can you tell me your views vis PM's

 

Thanks Mike

 

This point is a well put notification! I know there are certain members who have large plant vehicles. IE: Airfield graders, Etc.

Classified as plant & not allowed for in the present propsed legislation. They too, could fall foul of this proposal! These vehicles are few & far between as they are LARGE & thirsty. If they disapeared from the circuit, the likes may never be seen again.

As an aside, I personally have NO interest in Plant equipment. BUT, we should be banding together as a TEAM to inform those 'Powers that be'. Just because we own different classes of vehicle & there MAY be a mentality of, 'Well, it wont affect me' attitude. THIS DOES NOT MEAN IT MAY NOT IN THE FUTURE!

We have a chance here to affect & change the PROPOSSED legislation.

As the Honourable MP has stated perviously. 'If enough difficulties are rasied as to make this proposal too difficult or unworkable. It may all be abandoned'. (Or words to that effect!)

Just my two pennies worth! :-X

Mike

[antarmike]

So as its pre 1960 its still exempt as I understand it !

 

Will remain exempt if used unladen,and not towing a laden trailer.

 

At present can tow a laden trailer by virtue of being locomotive, If change goes through will stay exempt, just won't be able to tow laden trailer without testing.

Edited February 13, 2010 by antarmike

[AndyFowler]

Will remain exempt if used unladen,and not twing aladen trailer.

 

At present can tow a laden trailer by virtue of being locomotive, If change goes through will stay exempt, just won't be able to tow laden trailer without testing.

 

Well thats a relief ! I'm off to the shed now to carry on my lifes work ! Was just about to run it all in ! :-D We do seem to get a lot of great benefits complying with European legislation I might convert her to left hand drive while I'm at it !:-D:-D:-D

[Adam Elsdon]

The Story so far.

 

The proposal is to remove exemption from certain categories of HGV.

 

A large number of Forum members own one or more pre 1960 vehicle. This proposal will not affect them, if they currently use it unladen, and they do not draw a laden trailer. Still to be confirmed but the balance of probability is that a living van does not count as a laden trailer. But it has to have a permanently mounted bed, sink and cooker.

 

Some members who own mobile cranes of any age will be affected is an much as these will become testable.

 

So far no one has come forward to say they own a recovery vehicle. Recovery vehicles will become testable, but the definition of what is a recovery vehicle excludes most of the vehicles we view as Recovery vehicles. To be a recovery vehicle, it must have a Recovery vehicle Excise disc, and be used solely for recovery purposes. If there is any element of what you know as “Social, Domestic and Pleasure” use then it is not a recovery vehicle. I therefore, unless I hear otherwise cannot see that removing MOT exemption for this class affects us.

 

Vehicles Constructed primarily for …..Education, and Display use....(Special Project Vehicles). As yet no forum member has identified that they own a vehicle in this class. Unless I hear otherwise I am assuming that removal of MOT exemption for this class does not affect any Forum member.

 

No Forum member has come forward indicating that they consider their vehicle to be Engineering Plant. Likewise unless I hear to the contrary I assume no Forum Member is affected by the proposed removal of MOT exemption for this class.

 

Amongst the Forum membership, undoubtedly the group who are most affected are those who own Motor Tractors, Light Locomotives and Heavy Locomotives. The plan is to remove MOT exemption from this class of vehicle.

 

I think it is fair to identify three major types of ex military equipment falling under this banner.

 

Firstly wheeled Armour, AFV,s Scout Cars, Wheeled reconnaissance vehicles,( Fox, Ferret, Saladin, Saracen) APC's (although whether they fall under PSV legislation and are currently requiring testing, I am not totally sure)

 

Gun tractors, vehicles used by the Armed forces for recovery, but not fitting the definition of recovery vehicle mentioned in the proposal, and Ballast tractors, tank transporters (e.g. Diamond T 980/981) and the like, where these vehicles comply with construction and use regulations in terms of width etc.

 

Ballast tractors which fall outside Construction and Use Regulations because of width etc. (Antar, Rotinoff etc.) AILV's and the like. Vehicles that already carry an STGO Chassis plate.

 

I shall be stressing the distance vehicles will have to travel to be tested, the increase in costs for the owners, that will in percentage costs be far higher to private owners, than the figures stated for fleet operators. The slow speed and poor economy of these vehicles.

 

I shall be stressing the importance of testing vehicles, keeping in mind the original standards to which they were made, and the importance, on historically important vehicles of not having to modify them, to comply with standards and requirements that have been introduced after the vehicles were built.

 

I shall be stressing the peculiarities of odd-ball designs, and practices which were once commonplace but may well be beyond the experience or knowledge of this generations testers.

 

I shall be highlighting those vehicles were rolling road testing of brakes is impossible, those too wide to fit through the lanes at an HGV test centre, poor access into armoured cars, the limited usefulness of testing Armour, where much of what a tester may want to see is behind bolt on armour or floor plates.

 

I shall be emphasising our desire to see, if vehicles do have to be tested, that testers come to the vehicles, not Vice versa, particularly where an owner has a collection of vehicles, or owners in a locality can organise to get several vehicles to a site at the same time.

 

I will be suggesting, that in much the same way as Steam engine boiler inspectors are independent agents, that limited safety testing of ex military vehicles could be the responsibility of trade organisation or a network of suitably qualified individuals.

 

I will also be suggesting that, since annual mileage is low, wear and tear cannot be viewed as occurring at the same rate as Commercially operated vehicles, therefore testing could be extended to Bi-annual testing or longer.

 

I will be highlighting that they have produced no evidence that Ex Military vehicles are in a dis-proportionate amount of accidents, but rather, the best evidence of accident rate comes from insurance data, and the very low rates we are charged shows we are one of the safest groups on the road under present rules.

 

I have to be seen to support road safety improvements, and I cannot argue that vehicles that it is easy to test should not be tested. I can argue that as a whole, testers are unfamiliar with the technology of our vehicles, and will have problems testing a large number of them.

 

I will point out that the reason these exemption where granted in the first place was due to the limited amount of use on the roads there was by these classes, and that holds good for Military vehicles only attending a few shows per year.

 

I will also be stressing the loss in value to the owner, if a vehicle becomes mandatory MOT victim.

 

If they choose to pull out of the hobby because they cannot bear the extra cost these proposals will put on them, Then there vehicles will also have become less appealing to others, and will fetch a much lower price.

 

 

I welcome helpful comment, but please if you wish to pull this apart or challenge the basic way I am trying to deal with this please can you tell me your views vis PM's

 

Thanks Mike

 

Mike, i think this is a well planned out and relevant response that is within the parameters of the consultation requirement.

 

My only concern and you have pointed out the ommissions, that people may not be laying down their "Constructive opinion" for there own respective vehicles in the "Proposed MOT Regulation Vehicles List" Thread: http://hmvf.co.uk/forumvb/showthread.php?16901-Proposed-MOT-regulations-VEHICLE-LIST

[rbrtcrowther]

Many thanks mike:-) historic vehicle it will be and a drafty tent to pass out in at the field :yawn:

[antarmike]

Talking to Tim Holt, N.T.E.T. Rally co-ordinator last night.

 

Re any N.T.E.T. approved rally such as G.D.S.F., and legal requirement for a vehicle to have an MOT. There is no legal requirement under road traffic act as it applies to off road events, to have an MOT, although rally organisers are entitled to insist on one as their own personal requirement.

 

Those parts of road traffic act that do apply to Off road events to which public have access are the requirement to have a minimum of third party insurance cover, and to hold a licence for that class of vehicle.

 

No requirement for a vehicle to be taxed even, but at an off road event you can be found guilty of dangerous driving, driving without due care and attention, driving under inflence of drugs or drink.

 

It would seem that for HGV's arriving on low loader to an event, that currently do not need MOT, but which are prposed to loose exemption, then the Law does not require that they have MOT at an event, but the rally organisers might well require it as a condition of entry.

 

Road traffic act applies to all areas of a rally field, including the haulage playpen, so even in the relative security of the playpen, then the driver needs the correct licence, so everyone, beware of letting anyone drive your vehicle on a rally field unless thay have a current, valid driving licence for that class of vehicle.

[Adrian Barrell]

I assume this only applies to events where the public are admitted or at least pay to attend.

[antarmike]

I assume this only applies to events where the public are admitted or at least pay to attend.

 

If other vehicle owners are present, or stewards, they are considered to be public. If it is an organised event where people are present then the driver needs the correct licence.

 

At GDSF only exhibitors are allowed inside the playpen, but each exhibitor is both an exhibitor and a member of the public, so road traffic act applies inside this "restricted" area.

 

At a military show, where anyone can turn up with a suitable vehicle, whether they pay get get in through the gate or not, this makes them public.

 

As I understand it this means only H licence holders can drive tanks, although someone with provisional entitlement can drive provided the vehicle shows L plates.

 

Talking to the NTET, things aren't looking very good for steam preservation either. At present you need a driving licence for a steam road roller, but not for tractors, locomotives, showman's engine, ploughing engine and the like. New proposals now suggest that anyone driving any steam powered vehicle will have to pass a driving test, for a steam powered vehicle.

[ChasSomT.]

I know this isn't Mot related, but your post states drivers must have the correct licence for the CLASS of vehicle. This is an area that needs sorting out, surely?

Look at the discussions about how to classify wheeled armour - Ferrets, Saladins, Saracens and Stalwarts etc. The powers that be don't know how, where or even IF they need Mots.

Goods vehicles made before 1960 can be driven Unladen on a car licence.

Anything made before early January 1973 can be taxed Historic Vehicle, and I won't start on tracked vehicles.

After Mots have been sorted, there should be a further 'Consultation' on all these points, don't you think?

Just my opinion

 

Chas.

[Adrian Barrell]

If other vehicle owners are present, or stewards, they are considered to be public. If it is an organised event where people are present then the driver needs the correct licence.

 

.

 

 

This would mean, by extension, that if I invite some friends round for an afternoon to drive my vehicles in my field, RTA would apply. I do not believe this to be the case.

 

However, that is not the topic of this thread so I'll leave it there!

[antarmike]

This would mean, by extension, that if I invite some friends round for an afternoon to drive my vehicles in my field, RTA would apply. I do not believe this to be the case.

 

However, that is not the topic of this thread so I'll leave it there!

 

I agree not the subject of this topic, but just to round of this diversion, an event, at which RTA 1995 applies, and at which liability can be reduced by staging it under the NTET as the authorising body covers.

 

1. Event

The collective name used to cover Rally, Vintage Gathering, Exhibition, Show, Cavalcade, Fayre or Fair or

Old Time Fair, Steam Working and other Working Demonstrations, Gala, Match, 'Steam Party', 'Crank-up',

Road Run or any situation where exhibits are organised so as to form a presentation.

Exhibits must be covered by at least Public Liability insurance providing a minimum of £2,000,000

indemnity. Motorised and self-propelled exhibits must be compliant with the Road Traffic Acts for

Insurance and Licensing purposes, and carry the minimum third party insurance as required by the Road

Traffic Act.

 

as found here,

http://www.ntet.co.uk/pdf/rally_organisers_cop.pdf

Edited February 20, 2010 by antarmike

[ferretfixer]

I agree not the subject of this topic, but just to round of this diversion, an event, at which RTA 1995 applies, and at which liability can be reduced by staging it under the NTET as the authorising body covers.

 

1. Event

The collective name used to cover Rally, Vintage Gathering, Exhibition, Show, Cavalcade, Fayre or Fair or

Old Time Fair, Steam Working and other Working Demonstrations, Gala, Match, 'Steam Party', 'Crank-up',

Road Run or any situation where exhibits are organised so as to form a presentation.

Exhibits must be covered by at least Public Liability insurance providing a minimum of £2,000,000

indemnity. Motorised and self-propelled exhibits must be compliant with the Road Traffic Acts for

Insurance and Licensing purposes, and carry the minimum third party insurance as required by the Road

Traffic Act.

 

as found here,

http://www.ntet.co.uk/pdf/rally_organisers_cop.pdf

 

Just to add to the 'List'. PUBLIC PLACE = 'A Place where the Public have access, by Payment, Or Otherwise'. (legal Definition). :angel:

[gritineye]

Just to add to the 'List'. PUBLIC PLACE = 'A Place where the Public have access, by Payment, Or Otherwise'. (legal Definition). :angel:

 

So presumably if you own a field that has a footpath across it, then you can no longer let your kids play or learn to drive there using any form of motorised vehicle. Like wot we did...:-(

[Adrian Barrell]

I don't think that's the case. The sections of the RTA that apply relate to dangerous driving etc. If you are caught on the road driving normally but without a licence or tax etc, you are not charged with dangerous driving so all this ''RTA applies to anywhere'' is a red herring, IMHO!

[Steve 82]

Guys,

 

I have been out of UK for a little while and just caught up on this. Could someone please brief me on the current status of this.

 

Thanks

 

Steve

[antarmike]

Guys,

 

I have been out of UK for a little while and just caught up on this. Could someone please brief me on the current status of this.

 

Thanks

 

Steve

 

I have literally in the last few seconds sent Lee and Jack a copy of the response I feel the HMVF should make regarding these proposals. I await their comments before making any final adjustment to thee response and getting it away to those concerned.

[Marmite!!]

I have literally in the last few seconds sent Lee and Jack a copy of the response I feel the HMVF should make regarding these proposals. I await their comments before making any final adjustment to thee response and getting it away to those concerned.

 

Just read the document, excellent work Mike, thank you on behalf of HMVF & it's members for all the hours you have put into this & taking members concerns on-board.

 

We will discuss making the document available to interested members once Mike has submitted the response & receives confirmation of it's receipt.

[griff66]

i would certainly like to have a look at it.

[berna2vm]

Oh, how did that slip out...:wow:

 

What I meant to say was that a vehicle, as it gets older, should be classed as "Historic" but it's not. So mine being 25 years old in 2011 should be classed as Historic, but it never will be. :red:

If the late,great Alan Clark can be brought back from the other side, then maybe it will indeed....:cry:

[antarmike]

I have just had an email back from Robert Newman.

 

"Mike

 

 

 

Thanks, your response has been received and will be considered.

 

 

 

I’ve also had a response from the Military Vehicle Trust and I’m hoping to hear from the Federation of British Historic Vehicle Clubs before trying to arrange a meeting. But will invite them, and you, to a meeting soon anyway.

 

 

 

 

 

Robert Newman

 

Policy Advisor

 

Vehicle Roadworthiness and Enforcement Branch"

[Marmite!!]

Great work Mike...

 

I have just had an email back from Robert Newman.

 

"Mike

 

 

 

Thanks, your response has been received and will be considered.

 

 

 

I’ve also had a response from the Military Vehicle Trust and I’m hoping to hear from the Federation of British Historic Vehicle Clubs before trying to arrange a meeting. But will invite them, and you, to a meeting soon anyway.

 

 

 

 

 

Robert Newman

 

Policy Advisor

 

Vehicle Roadworthiness and Enforcement Branch"

[griff66]

thanks for all the hard work mike , is your/our proposal going to be put on the forum for our perusal ?