important MOT Testing Exemptions Consultation VERY IMPORTANT

[antarmike]

heres another possible anomaly in the consultation document chap 4 subsection 4.3 (the proposals) it talks about modifying rta 1988 so that motor tractors and heavy and light locos are no longer from exempt from annual roadworhiness testing IN ANY CASE WHERE A VEHICLE IS BASED ON A HGV STYLE CHASSIS AND WOULD THEREFORE BE REGARDED AS A GOODS VEHICLE.so post 1960 ferret for example would be still exempt cause not hgv based ,not a goods vehicle. etc? thoughts?:cool2:

 

Good point, that hadn't struck me.well done.

[antarmike]

John Attlee, Viscount Pretwood rang me this evening, he want's everyone to know that he is going to do what he can.

 

He says that DfT are not in a position where they can do nothing. Things have to change, and the best we can do is to persuade DfT to mitigate the effects, the financial loss to ourselves etc of these proposals. These proposals will go ahead in some form or other, but we have a chance of gaining some conciderations for older , non commercial vehicles.

 

John has asked me to forward to him, all the problem vehicles, and anomallies that will make testing difficult, expensive, virtually impossible. So keep posting me the vehicles you have and the problems you foresee in testing them., in the Proposel HGV teasting Vehicle list thread.

Edited February 3, 2010 by antarmike

[LoggyDriver]

Brake test, will the examiner be prepared to drive the vehicle using a Tapley meter? will an examiner be familiar with driving this type of vehicle (preselect) will an examiner even be able to get in the Fox (getting out is even harder) a lot try to get in the Fox & find it impossible, will he carry out the brake test with a commander as a lookout??

 

Will the headlights comply? mounted inboard above the bumper & same wattage hi & low beam.

 

No mudflaps.

 

Emission test required?? will it comply?

 

I presume that they will want to have a look around the engine bay... they will have to traverse the turret to do that.

 

Will the Cannon sticking out 3' in front of the vehicle comply??

 

Most of the hard brake lines are hidden under floor plates & covers... do they need to check these?

 

 

 

 

When you take a vehicle to VOSA for testing, VOSA don't drive the vehicle through the garage, YOU DO. The owner has to drive it onto the rollers for the brake test, the owner has to rev the engine for the emissions and operate the lights etc.

 

They can only test items that are visible and accessible. So if you have an engine inside an engine bay that has access hatches that are bolted shut, they cant test what's behind it. The same goes for floor plates and covers. My mate had an armoured lightweight that had a belly plate fitted. They couldn't check the props, steering linkage, exhaust etc due to this. As it's part of the vehicle they can't ask you to remove it.

Edited February 3, 2010 by LoggyDriver
spelling

[Marmite!!]

as regards actual testing, then speaking from experience of having my Ferret (voluntarily) tested at a VOSA HGV test station:

- you are expected to drive it, not the examiner,

 

To clarify whether the inspector needs to be able to sit in a Fox CVR(W)...

 

So the vehicle owner drives it into the inspection bay & sits in the drivers seat & operates the lights etc during the test??

 

How does the examiner know the vehicle is being driven at the correct speed when the brakes are to be applied for the brake test... not that I even know how a Tapley meter even works????

Edited February 3, 2010 by Marmite!!

[antarmike]

To clarify whether the inspector needs to be able to sit in a Fox CVR(W)...

 

So the vehicle owner drives it into the inspection bay & sits in the drivers seat & operates the lights etc during the test??

 

How does the examiner know the vehicle is being driven at the correct speed when the brakes are to be applied for the brake test... not that I even know how a Tapley meter even works????

 

I talked to John Attlee tonight, He has had Tapley tests done. He says there is no problem withthem, they work, there appears to be no set speed,(but I beieve a minimum speed of 15 mPH has to be reached) it is a matter of judgement on the part of the tester, knowing the vehicle and the space available to him Hand brake is tested on the artificial hill at all test centres.

 

http://www.tttonline.com/product/brake%20gauges%20and%20tools/Tapley.htm

or the modern version thereof

http://www.aideautomotive.com/products/commercial_vehicle/brakecheck.php

 

I think it is a bit like the controlled stop in the HGV test, where you drive and accelerate to 30 mph before reaching the marker then brake in a controlled manner. In the HGV test the examiner is outside the vehicle at the time but he has done that many he instinctively know what 30 MPH looks like!

Edited February 4, 2010 by antarmike

[cosrec]

I think the biggest problem with the proposed changes to mot regs on this forum is a fear of the unknown.

 

Instead of thinking of ways of thinking of ways of getting out of testing vehicles why not do a check round and present it.

Instead of thinking how are they going test this or that forget about it thats their problem not yours.

Once you have seen how the tests are conducted mainly on the braking side you will agree if it fails it should not be driven on the road.

One other thing i have noticed is an excuse for being exempt from mot on historic vehicles is that it will cost me this much to make it roadworthy. Now iam not a clever person but if i was proposing changes to mot regs this would not cut much ice with me. Why is it still being driven around

lastly when it does pass you will have a smug grin on your face as you drive out

Edited February 4, 2010 by cosrec
missed a bit

[griff66]

do we know for definite if a 1964 vehicle for example will be tested as 1964 vehicle as regards to emissions brakes etc, and where do they get the data for the brake efficiency tests ?

[griff66]

antarmike, do you think viscount pretwood will raise our concerns in the lords/

[Dave]

Clearly affected are Diamond T 980/981. Although pre 1960, there exeption is not based on being a pre 1960 vehicle, used unladen. These are not goods vehicles, they are locomotives, not being designed, themselves, to carry a load. At the moment exempy due to being a Loco. that is prposed to change.

 

Diamond T 969, currently exempt, (recovery vehicle) but due to become mandatory tested.

 

And I just want to say there are some out there who seem a bit complacent, saying it doesn't affect me. No-one knows how their life will pan out and many aspire to own a larger vehicle. This needs fighting, not just because of wehat you own, but also what you might end up owning one day in the future!

 

You make a point i`d previously overlooked Mike.

I was happily reading all these posts thinking that i was ok because my Diamond T 981 was ok because of its age, but then as you correctly point out they will still collar me for the fact that it`s a locomotive, (irrespective of it`s age)

Once again they get you one way or another.

One question which throws even more confusion my way is my living van based on a later arrows 1 3/4Ton trailer. if i`ve got it right it won`t need testing if i tow it behind my 101 ( max towing weight 2 tons according to the vehicle data plate) but it will if i tow it behind the T.

[gritineye]

One question which throws even more confusion my way is my living van based on a later arrows 1 3/4Ton trailer. if i`ve got it right it won`t need testing if i tow it behind my 101 ( max towing weight 2 tons according to the vehicle data plate) but it will if i tow it behind the T.

 

As I see it, over run braked trailers (Arrows) will remain exempted.

 

Living vans are exempted, a living van has to have a bed, sink, and cooker fixed into it, personal kit can be carried as well a a pay load. (historic vehicles tax exempt must not carry a pay load) The payload is what distinguishes it from a caravan.

 

A living van can be self propelled, that is why it has an asterisk in the list of unchanged exemptions.

 

One other thing i have noticed is an excuse for being exempt from mot on historic vehicles is that it will cost me this much to make it roadworthy. Now iam not a clever person but if i was proposing changes to mot regs this would not cut much ice with me. Why is it still being driven around

lastly when it does pass you will have a smug grin on your face as you drive out

 

I certainly don't think it is the cost of making them roadworthy that worries us, most are over maintained just for the love of it, it is the cost of maybe having to meeting modern C&U requirements with historic vehicles. We are just asking for clarity here.

Oh and then there's the not so small problem of being pulled over and caught out by the small print and getting fined for some unforeseen infringement of these new rules, which would most likely make us uninsured as well!

[john fox]

To clarify whether the inspector needs to be able to sit in a Fox CVR(W)...

So the vehicle owner drives it into the inspection bay & sits in the drivers seat & operates the lights etc during the test??

How does the examiner know the vehicle is being driven at the correct speed when the brakes are to be applied for the brake test... not that I even know how a Tapley meter even works????

 

as per Mike's response, the examiner (an ex REME mech in my case) made me do the drive by several times as he considered I was not going fast enough - becuase he knew how much inertia a Ferret has once you come off the gas, he required me to do it at 20mph, and spotted I was not that fast initally - it seems a short yard from a standing start in a Ferret!

 

examiner does of course have to sit in the drivers seat at some point to confirm operation of the instrument tell tales but the next time I had it done all they did was sit outside and look in while I turned them on

 

positioning the tapley took care because it should be level and secure but he did not want it on the floor of the vehicle becuase that was too low and would give a poor reading, conversley putting it on the turret top was too high - its works by measuring angular motion so position in relation to vehicle CoG matters. Compromise was to secure it on the wing but this was quite a work of art first time, I took small ratchet straps with me second time.

Edited February 4, 2010 by john fox

[gritineye]

An Explorer will remain exempted as pre 1960.

"motor vehicles first used before 1.1.60 and trailers manufactured before 1.1.60" is a category of vehicle exempted from the "sched 2 goods vehicles (plating and testing) regulations 1988"

note that "breakdown vehicles" "cranes (mobile)" and "track-laying vehicles" are, currently, in the same list of exempted vehicles. The idea that the pre 1960 exemption does not apply to vehicles that are not goods vehicles is wrong, otherwise brakedowns, cranes, tracked etc would also not qualify for exemption, as they are not goods vehicles.

A vehicle does not have to be a goods vehicle to be exempt from the regulations, it has to be in one of the exempted categorys.

It is a selection of these categorys that are being reviewed by this consultation, the pre '60 category is not being reviewed.

 

Thanks Croc

 

I have been re-reading the rules and talking to people including Steve (croc) and I have revised my position. The Pre 1960 exemption is for ANY motor vehicle used unladen.

 

Although built as a recovery, an explorer is only classed as one in C and U terms if it complies with the Vehicle Excise regs in all respects regarding recovery vehicles. A recovery vehicle is only a recovery vehicle, if it is taxed as one.

 

Most Scammell explorers are therefore Not recovery vehicles according to C and U definitions, Neither are Martians, Militant Mk3, Ward laFrance M1A1, Diamond T 969 etc.

 

At present you only have exemption for this type of vehicle via the Recovery Vehicle route if the tax disc in the window says recovery, and it is actually only ever used for recovery. AT present these vehicles have exemption by being locomotives.

 

I think I've got it now, but these things are exactly what we need to have officially spelled out for us in plain English at the end of this consultation process once and for all. That's not to much to ask is it?

 

MY head hurts now..........:-(

[john fox]

Good point, that hadn't struck me.well done.

third para of my post #77,

Edited February 7, 2010 by john fox

[griff66]

00ec25, its good that we are spotting all these problem areas ,anomalies .

[griff66]

have just received a very interesting email will post later , VERY INTERESTING.:cool2:

[Stone]

I think it is a bit like the controlled stop in the HGV test, where you drive and accelerate to 30 mph before reaching the marker then brake in a controlled manner. In the HGV test the examiner is outside the vehicle at the time but he has done that many he instinctively know what 30 MPH looks like!

LGV test controlled braking exercise is done with the examiner inside the vehicle - at least it was for me, twice, mid-2009.

 

Stone

[Poptopshed]

Yes, the examiner remains in the cab during the brake test part of the HGV licence test. They only get out to observe the reverse test.

[antarmike]

LGV test controlled braking exercise is done with the examiner inside the vehicle - at least it was for me, twice, mid-2009.

 

Stone

 

That is not how I remember doing mine...

[radiomike7]

They can only test items that are visible and accessible. So if you have an engine inside an engine bay that has access hatches that are bolted shut, they cant test what's behind it. The same goes for floor plates and covers. My mate had an armoured lightweight that had a belly plate fitted. They couldn't check the props, steering linkage, exhaust etc due to this. As it's part of the vehicle they can't ask you to remove it.

 

So did they pass it, refuse to test it or tell him to come back once he had made the vital bits accessible? Common sense dictates that you cannot pass something that you have not inspected.

[croc]

do we know for definite if a 1964 vehicle for example will be tested as 1964 vehicle as regards to emissions brakes etc, and where do they get the data for the brake efficiency tests ?

 

Yes it will be treated as per its age.

The consultation is about removing exemptions, not adding regulations. The Construction and Use regulations have various age qualifiers. For example, Speedometers must be fitted to all vehicles, with some exeptions. Vehicles first used before 1.10.1937, motor cycle first used before 1.4.1984, maximum speed not exceeding 25mph, among others.

 

The C&U regulations and the Road Vehicle Lighting regulations are the rules that have to be followed when a vehicle is tested. They are long winded but it is worth reading through them to be able to form a sensible opinion of which rules apply to each vehicle. There is a book available, "The Traffic Officers Companion" by Gordon Wilson, that gives a condensed working version of the various acts. Antarmike recomended it to me a few years ago, I would say it was a very worthwhile purchase.

[antarmike]

You make a point i`d previously overlooked Mike.

I was happily reading all these posts thinking that i was ok because my Diamond T 981 was ok because of its age, but then as you correctly point out they will still collar me for the fact that it`s a locomotive, (irrespective of it`s age)

Once again they get you one way or another.

One question which throws even more confusion my way is my living van based on a later arrows 1 3/4Ton trailer. if i`ve got it right it won`t need testing if i tow it behind my 101 ( max towing weight 2 tons according to the vehicle data plate) but it will if i tow it behind the T.

 

As far as I know living vans under 3500Kgs are exempt testing.

[antarmike]

antarmike, do you think viscount pretwood will raise our concerns in the lords/

 

I don't think that the process has gone far enough for that yet. John is pseaking to those closely involved in the consultation process at present.

[No Signals]

Rather than sit round talking about it I put together a polite and considered response to the proposals. I received this response today-

 

Thank you for your response to the HGV MOT testing consultation.

 

We have had a number of responses from historic vehicle owners. It was not the intention of these proposals to catch such people and we will be working with relevant organisations and experts to ensure that we only catch those types of vehicle that were intended. Which is not to promise that everybody who currently claims to have an exempt historic vehicle will avoid the categories we are seeking to change. But broadly we are looking at vehicles that look and behave like HGVs, not the wide variety of private collector’s vehicles that you refer to.

 

Your comments on the cost and benefits will be looked at, in conjunction with others, when the consultation period finishes on 19 March.

[griff66]

Hi Guys

 

I have been on to the DVLA and just today received the following response:

 

MY 1ST EMAIL TO DVLA sent 29 jan 18.47p.m.

 

Dear sir, madam

 

It has come to my notice that there is a consultation document about HGV mot exemptions. As a owner of a ex military vehicle this will affect me and countless others.

 

Can I suggest that you get in touch with Military vehicle trust, who are a DVLA approved club, as a lot of these

vehicles are part of this countries history and this would be a death knell for the hobby.

 

Thank you.

 

Paul

 

 

 

MY 2ND EMAIL TO DVLA sent 30 jan 08.12.a.m.

 

Joanne,

 

This relates to the DVLA consultation going on about MOT exemptions

(HGV.)

 

I have a 1964 Daimler Ferret ex military vehicle weighs approx 3700kg and I

think, at moment, VOSA class it as a motor tractor. I go to 10 approx shows a year covering, at most, 1000 miles a year, as it is a hobby.

 

Will my Ferret, if this goes ahead, be tested as a 1964 vehicle or a modern one? Is there going to be money to out fit new test stations to accommodate these unusual vehicles? Will there be an exemption for NON commercial users? This is a hobby not a business.

 

And finally, have you consulted with military vehicle clubs?

 

Looking fwd to your reply.

 

Paul

 

 

 

RESPONSE FROM DVLA

 

Dear Paul

 

Thanks for your responses to our consultation.

 

I've also had a look at the comments on the HMVF thread that you started.

 

Broadly, the intention of this consultation is to look at those vehicles that look like an HGV and act like an HGV but are currently exempt from plating and testing.

 

It is not our intention to catch or persecute historic vehicle owners. It is not our intention that a Daimler Ferret's status would be changed by these proposals. I'm sure that most historic vehicles will remain outside the regulations. However it is possible that a few of your colleagues might get caught by our proposals.

 

At this stage we are only consulting and will adjust our proposals according to responses received. We have received a number of emails from historic vehicle owners and will talk fully with relevant organisations that represent your interests to ensure that we don't catch people that were not the intended targets.

 

The question you raise about VOSA being able to accommodate unusual vehicles is also one that has to be looked at in detail. We are not going to try to introduce new rules that it is then impossible for VOSA to comply with.

 

Once we draft new regulations there will have to be a second consultation to go with the proposed new legislation. This will happen towards the end of this year at the earliest, depending on how complicated getting definitions clear turns out to be.

 

The consultation doesn't end until March 19 and we welcome all responses from individuals or organisations until then. We will be talking further and meeting with key stakeholders after that date.

 

I hope that this goes some way towards reassuring you.

 

 

Robert Newman

Policy Advisor

Vehicle Roadworthiness and Enforcement Branch

Zone 2/09

Great Minster House

76 Marsham Street

London

SW1P 4DR

Tel: 020 7944 6575

 

Useful websites:

Department for Transport - http://www.dft.gov.uk

Transport Office - http://www.transportoffice.gov.uk

Directgov - http://www.direct.gov.uk

Edited February 4, 2010 by griff66

[griff66]

no signals, i dont think any one has just been sitting around talking about this.:cool2: