important MOT Testing Exemptions Consultation VERY IMPORTANT

[Marmite!!]

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

 

Under discussion...

[N.O.S.]

Sorry, but what's to discuss? If it purports to REPRESENT the Forum, surely it should be ON the forum, or at least made available to forum members.

 

I think the majority of us are grown-up enough not to criticise our Latin Teacher's lecture notes :-D

 

If there are valid concerns about putting it on, perhaps it could be made available to members by PM upon request, with a committment from those folk not to copy it elsewhere? I'd certainly be happy with that arrangement.

[AndyFowler]

I agree Tony !

[Marmite!!]

Sorry, but what's to discuss? If it purports to REPRESENT the Forum, surely it should be ON the forum, or at least made available to forum members.

 

I think the majority of us are grown-up enough not to criticise our Latin Teacher's lecture notes :-D

 

If there are valid concerns about putting it on, perhaps it could be made available to members by PM upon request, with a committment from those folk not to copy it elsewhere? I'd certainly be happy with that arrangement.

 

That's what we are discussing... it's a very long document & we are just sorting out the best way for the members to receive it... It WILL be made available in due course.

[utt61]

...

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

 

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.

...

 

 

Mike,

 

First off, very many thanks for the sterling work you have done on behalf of all of us on this matter, it is appreciated more than mere words can adequately express. Thank you.

 

I have mentioned briefly earlier in the thread my Iron Fairy crane (briefly since despite being ex-ROF it is not really an MV and I worry that as a result I am straying outside the scope of this group) in the belief that it is a Mobile Crane - this is indeed what DVLA/VOSA seem to believe at present.

 

However, after reading the Special Types regulations I am now convinced that it is NOT a mobile crane! I am not sure exactly what it is, but a mobile crane is required to have suspension and an Iron fairy does not. It is possible it may be engineering plant, but I need to have a better look through the ST regs to try to figure this out.

 

It weights 12 tons, cannot carry a load (except on the hook), has a top speed of 12mph, has no suspension (but is on pneumatic tyres), has number plates, lights etc, is taxed as Historic vehicle, insured (actually as 'van' since the insurer has no better matching description). It is completely impractical to drive it to the nearest MOT test centre without causing traffic chaos and falling foul of the Drivers Hours regs. I have absolutely no idea where I stand at the moment! I believe it to be MOT exempt at the moment, but no longer really know why!

 

The chances of me ever wanting to drive it any distance on the road are remote, but I do need to be able to make regular short journeys (1/4 mile each way) to move it between yard/storage areas. If in the future it needs an MOT I have a big problem!

 

I had the opportunity to speak to a traffic policeman last weekend and asked him for his opinion. His reply was that he hadn't a clue, but if he'd stopped it on the road and it *appeared* to be legal (ie tax disc, insurance, lights etc working) he would let it go because it wouldn't be worth wasting the time to establish the real situation! Not the answer I was hoping for, but intersting none-the-less.

[rbrtcrowther]

Our old crane is a coles hydra husky 18 ton. has rocking beam suspension and used to manage 25 mph on a good day. It is a special vehicle and needs no mot. Our slighty newer crane has road springs and will manage 60mph on a really good day. not sure what it is registered has but has never seen an mot station. shouldent worry too much about you crane.

[utt61]

I notice reading the Special Types regs that a 'mobile crane' and 'engineering plant' can be up to 6.1 metres wide and 30 metres long and weigh up to 150,000kgs! That would be quite something to meet coming towards you.

[rbrtcrowther]

Quite something to try and put on a brake tester too:wow:

[Marmite!!]

With many thanks to Mike (AntarMike) a copy of the MOT Consultation Response is available here...

http://hmvf.co.uk/forumvb/showthread.php?17699-MOT-Consultation-Response-(Document)

[griff66]

thanks for posting document

[ChasSomT.]

Yes, Well done AntarMike, many thanks for all your hard work.

[Steve 82]

AntarMike,

 

Many thanks for taking the time in the preparation the response document - contains well thought out arguments on all points addressed.

 

Steve 82

[antarmike]

I am invited to attend a meeting in London to take this further. Having read my response so far, if anyone has any thoughts as the matters needing addressing in a face to face meeting, Corrections addendums etc, now is your time to say. Meeting is on 31st of this month....

[griff66]

hi mark all looks good, just to reiterate a point, purpose of consultation was to remove exemption from hgv based vehicles, ferret, fox, saladin, sarracen etc, as has been discussed before, are clearly not hgv based therefore unfairly caught up in all this . perhaps a new class could be ,, ex fighting vehicles ,, and a consultation group to draw up a list of fighting vehicles that are applicable .

[ChasSomT.]

I don't want to broaden this too much, but an 'Ex Fighting Vehicle ' class would go a long way to removing some of the 'anomalies' re Tracked vehicles. If you could get 'Them' to look at this now, with reference to wheeled AFVs, it makes sense to consider tracks, if only to save having to go over the same ground sometime in the future.

Edited March 20, 2010 by ChasSomT.
Continuity with previous post!

[LoggyDriver]

Thanks for your time in preparing the document. All the arguments seem well thought out and the responses well put.

 

This isn't a criticism, but I would like to see the document proof read if possible for spelling and grammar mistakes, as I did notice a few and it should be as accurate as possible before submission to the Government. (but don't ask me as I can't spell):-\

 

I do take issue with your comment about "half asleep" HGV drivers though. I am an HGV class one driver and have been a Professional Driver since 1993, eight of those years as a driver in the Army. Whilst I accept that drivers do get tired and sometimes cause accidents, the milage driven per year versus the accidents that happen, would result in a small overall percentage and this is a rather sweeping statement. Trucks on "the limiter" means 56mph, and if a Reo is driving at 50mph this is only a 6mph difference. Lets not speculate on what a particular vehicle was doing to cause an accident as we don't know the facts. We are also subject to 5 yearly medicals over the age of 45 and this includes an eye test. It has to be remembered that Professional Drivers have taken the relevent training to pass their tests and as such are awarded their vocational licence. We are subject to drivers and working time regulations and now subject to the CPC training regime. We are being constantly trained and assessed for our driving skills and knowledge of the laws governing commercial vehicle operation. It has to be remembered that "most" collectors driving pre 1960 vehicles are driving very large machines WITHOUT an HGV licence and the training that goes with it.

Edited March 20, 2010 by LoggyDriver

[antarmike]

Thanks for your time in preparing the document. All the arguments seem well thought out and the responses well put.

 

This isn't a criticism, but I would like to see the document proof read if possible for spelling and grammar mistakes, as I did notice a few and it should be as accurate as possible before submission to the Government. (but don't ask me as I can't spell):-\

 

I do take issue with your comment about "half asleep" HGV drivers though. I am an HGV class one driver and have been a Professional Driver since 1993, eight of those years as a driver in the Army. Whilst I accept that drivers do get tired and sometimes cause accidents, the milage driven per year versus the accidents that happen, would result in a small overall percentage and this is a rather sweeping statement. It has to be remembered that Professional Drivers have taken the relevent training to pass their tests and as such are awarded their vocational licence. We are subject to drivers and working time regulations and now subject to the CPC regulations. We are being constantly trained and assessed for our driving skills and knowledge of the laws governing commercial vehicle operation. It has to be remembered that "most" collectors driving pre 1960 vehicles are driving very large machines WITHOUT an HGV licence and the training that goes with it.

 

Re Half Asleep, this relates purely to the drivers who are involved in rear end shunts. Those drivers that do ram into the back of slower vehicles must have a reason for doing so. If they are not half asleep, (or fully asleep) why do they do it?

 

Re spelling, the word "roadworthiness", a word much used in the consultation document, throws up as incorrect when I run my Spile Chucker, so I wouldn't be that concerned about spelling! I did run a spell checker on my response, and thought I had got the mistooks!!

Edited March 21, 2010 by antarmike

[Marmite!!]

Here's a Professional HGV driver for you, in case anyone missed the news this week..

 

 

 

http://news.sky.com/skynews/Home/UK-News/Lorry-Shunting-Car-Video-Arclid-Launch-Probe-Into-Truck-Pushing-Renault-Clio-Along-A1M-Wetherby/Article/201003315576181?lid=ARTICLE_15576181_LorryShuntingCarVideo:ArclidLaunchProbeIntoTruckPushingRenaultClioAlongA1(M),Wetherby&lpos=searchresults

 

Watch any of those Road War/Police stop type programs & it is full of HGV drivers either half asleep or showing atrocious driving... travel up any motorway & you can witness it yourself every day...

Edited March 20, 2010 by Marmite!!

[ferretfixer]

hi mark all looks good, just to reiterate a point, purpose of consultation was to remove exemption from hgv based vehicles, ferret, fox, saladin, sarracen etc, as has been discussed before, are clearly not hgv based therefore unfairly caught up in all this . perhaps a new class could be ,, ex fighting vehicles ,, and a consultation group to draw up a list of fighting vehicles that are applicable .

 

I can see a small but important segment here that could cause problems. With reference to 'Draw up a list of fighting vehicles that are applicable'. A list need NOT be drawn up. BUT, the reference to EX Fighting vehicles is good. The reason being, if you just have a LIST. then that is the only types that may be then exempted. BUT, if you include FIGHTING VEHICLES, per say. The this will allow the Future importing & usage of potential marks that we do not have at present. There are indeed Armoured Vehicles in Foreign Service that have not yet been released. This will as a natural process of introducing new Marks, make those in present service redundant & be sold off as Obsolete. These would (Hopefully) then reach the collectors market to be restored & put on the road. THIS MAY NOT HAPPEN IF WE JUST HAVE A RIDGID LIST!

So wording here I think is important. Feel free to correct me if I am wrong, but as we are almost all aware. When it comes to legal Battles, sometimes WORDING is everything! :undecided:

Just My personal observation: Mike.

[antarmike]

I can see a small but important segment here that could cause problems. With reference to 'Draw up a list of fighting vehicles that are applicable'. A list need NOT be drawn up. BUT, the reference to EX Fighting vehicles is good. The reason being, if you just have a LIST. then that is the only types that may be then exempted. BUT, if you include FIGHTING VEHICLES, per say. The this will allow the Future importing & usage of potential marks that we do not have at present. There are indeed Armoured Vehicles in Foreign Service that have not yet been released. This will as a natural process of introducing new Marks, make those in present service redundant & be sold off as Obsolete. These would (Hopefully) then reach the collectors market to be restored & put on the road. THIS MAY NOT HAPPEN IF WE JUST HAVE A RIDGID LIST!

So wording here I think is important. Feel free to correct me if I am wrong, but as we are almost all aware. When it comes to legal Battles, sometimes WORDING is everything! :undecided:

Just My personal observation: Mike.

 

One of the aims of the consultation document is to limit the number of MOT exempt vehicles that is growing all the time. I think it will be hard to argue that all vehicles now in service, when they are released, should be MOT exempt.

 

I think the best hope is to argue for the retention of MOT exemption for those vehicles already preserved and on the show circuit.

 

It is clearly against the spirit of the consultation to try to include new vehicles into a classification, in such a way that it will cause the number of MOT exempt vehicles to grow.

 

Remember that a simple category like ex Fighting vehicles would include a lot of fairly conventional goods vehicles, and trucks that can easily be tested (and should be tested) , It would be hard to argue that when say a DAF 4x4 or a Bedford TM is released to a collector it should be MOT exempt, but if the same vehicle is bought by a commercial firm, for carrying goods it should be tested. The need is to filter out those vehicles that cannot be easily tested, those which are older, and have different engineering standards to the trucks testers are used to seeing, and the like, but still apply testing to more modern vehicles which are relatively modern in terms of engineering, and easy to test.

 

A category of "ex fighting vehicles" will NOT achieve this.

Edited March 21, 2010 by antarmike

[Marmite!!]

Also don't forget if you are a member of IMPS or MVT to also let them know your concerns so that they can also speak on your behalf..

[David Ives]

a very well thought out reply

thanks

 

 

and as for the profesional drivers bit that have come up

most of us professional drivers stick to the rules and it is only a few that end up doing silly things because they dont obey the rules that are there to safeguard everyone:mad::mad::mad:

most important taking the full rest time and getting enougth sleep between duties:-X

if i have been moving somewhere to meet a coach and driving a car/minibus then that time comes under my 15 hour day and all companys that i work for know that and agree and before i take over a vehicle i take a 45 min rest

but that is my choice and i know some companys that say drive to work then start a 15 hour day:red:

[ChasSomT.]

Ref post #295 AntarMike - yebbut the Mot exemption 'consultation' is for HGV based vehicles. The proposed category of 'Ex Fighting Vehicles' COULD exclude HGV based vehicles.

[ArtistsRifles]

Ref post #295 AntarMike - yebbut the Mot exemption 'consultation' is for HGV based vehicles. The proposed category of 'Ex Fighting Vehicles' COULD exclude HGV based vehicles.

 

Following Mike (FerretFixers) sentiment about the wording being everything - rather than just "ex-Military Vehicles" why not use a more defined description along the lines of "Vehicles purpose designed & built for military service" - or words to that effect. That rules out civilian based vehicles such as Bedfords, Dafs etc. but covers things like Scammells, Fodens, armour etc. and leaves room for anything foreign that might come under the some description like the DAF artillery tractors or Maz/Kraz transporters.

[antarmike]

Following Mike (FerretFixers) sentiment about the wording being everything - rather than just "ex-Military Vehicles" why not use a more defined description along the lines of "Vehicles purpose designed & built for military service" - or words to that effect. That rules out civilian based vehicles such as Bedfords, Dafs etc. but covers things like Scammells, Fodens, armour etc. and leaves room for anything foreign that might come under the some description like the DAF artillery tractors or Maz/Kraz transporters.

 

What is the arguement for not testing fairly modern Scammells (S26 and the like) and Fodens just coming out of service? Why should DAF Artillery tractor, Maz and Kraz not be tested? If it is practical to test a vehicle, then the arguement is that it should be tested. Civilian operators of Ex Military Foden Recovery vehicles will need to MOT them if this proposal goes through. Why, if an operator has to MOT one, should a private collector expect not to have to?

 

The discussion document asked for representations to be made on behalf of vehicles that it would be difficult/ impossible to test. And it is these vehicles that that need to be kept out of the testing regime.

 

We have to keep in our sights what the aim of the consultation document was, and stop trying to make it an opportunity to allow anything and everthing we fancy buying or wish to own onto the road, without testing, if testing is possible.

 

I have to argue that HMVF Supports moves to improve vehicle safety and reduce accidents, and that we are not against testing just for the sake of it, we support testing where it is practical, where it does not put an unfair financial burdenon the owner, or where the vehicle is engineered in such a way as to comply with modern practice and standards.

 

I have to argue that HMVF, even though it supports MOT testing in general principle, does not feel that certain vehicles, because of their design, or other valid reasons, that have until now been MOT exempt, should become liable for MOT testing.

 

I would like us all to try and keep an eye on the ball, and not try and turn the consultation into something it isn't..

Edited March 20, 2010 by antarmike