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Proposed MOT regulations VEHICLE LIST


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On Stalwarts:

 

Permanent 6 wheel drive so cannot be used on rolling road brake testers. Would need to be used with a Tapley meter in the cab.

Problem there is getting into the cab - it means climbing up the side and in through the roof, no other access is viable. H&S would have a fit at employed people having to do that!

 

Most rigid brake lines are under the floor - engine decks can be lifted - cab floor plates would need to be unbolted - again not viable for a test scenario.

 

Like the other members of the FV-600 family any test on a wheel or steering means jacking the vehicle up so that the front 4 wheels are clear. Time required to do this - and safely support the vehicle - would take up a test station for longer than viable period of time.

 

When I bought her I rang the HGV testing station at Purfleet - after describing these and other points to them they told me the vehicle was MOT exempt as they had no way of testing it so, since 2006, I've used the V112G.

 

As regards over-width - books say it is 8' 7" wide (103" or 2.62 metres) - if VOSA/DVLA are now going to say they can longer be used on roads purely on a consultative whim then there will be hell to pay with owners of anything classed as over-width.

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sorry just dont see how a ferret can be classed as a heavy goods vehicle when it is not.

 

VOSA do not have a category for MV in civilian ownership, as all MV still in service are exempt by virtue of being in service, so it is not necessary to have a category for them as civilian ownership was never considered, so as a compromise solution they class Ferret as a motor tractor, which is a form of HGV.

 

It must go the "HGV route" becuase only a VOSA test station can legitimately test vehicles of such weight, a class 4 (<3000kg) or class 7 (weight between 3000 - 3500 kg) MOT certificate is invalid as the incorrect test has been performed since Ferret weighs >3500 and must have a HGV test or HGV test exemption.

 

 

A Stalwart on the other hand has more of a problem since it clearly is a goods carrier so cannot be a Section 185 vehicle, ie a locomotive,

Edited by john fox
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if you read all of post 149 on the other thread about this matter you will see that it is NOT there intension that a ferrets status will be changed by these proposals at all !

It is not the "intention" to alter its satus, but at the moment that is the result of the intended changes as currently worded.

 

Unless the wording is changed, then Ferrets will loose exemption..

 

What Robert Newman said to me is that a form of words has to be found that will leave the right vehicles exempted, but catch the target group. He says this requires precise wording, but even so he cannot guarantee that some of the vehicles that are not intended to be excluded, will nevertheless become excluded, because it may not be possible to find a form of words that satisfies 100% of what is intended. But it is hoped that a form of words can be found whereby a large majority of the vehicles not intended to change status, will be left excluded.

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A Stalwart on the other hand has more of a problem since it clearly is a goods carrier so cannot be a Section 185 vehicle, ie a locomotive, and therefore, whilst a test station has the power to refuse to test a vehicle if they consider it is not possible to do so, this does not automatically confer exempt status on it

 

I'm getting a bit confused over this - the consultation document refers to "HGV Based vehicles" which I would take to mean anything that has it's basis in a vehicle designed from the get-go as a HGV or load carrier. This is not the case with the Stalwart - it came from the same base design that gave us the Saracen and Saladin. These preceded it into construction therefore it is manifestly NOT based on a HGV design, but is adapted from from an existing AFV design - same as the Salamander.

 

And if I am willing to take a (currently) taxed/insured vehicle to an approved MOT testing Station - but said station declines to test it because they cannot - where does that leave me and all the other Stalwart owners/ In fact - the Saladin and Saracen ones too as the same objections raised by the testing station apply- viz. they are not allowed to climb onto the vehicle to gain entry and have no facilities for the computerised testing of permanent 6 wheel drive vehicles ( I was told by our local car MOT station this week that VOSA are tightening the MOT regs such that Tapley meters may possibly no longer permitted as the reading from the brake rollers have to be recorded as part of the test results and in view of this discussion I asked if this would apply to the HGV tests as well - he thought that it did - might be worth querying this ??).

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There should be no confusion over whether Stalwarts will be caught up in this - they clearly are not based on an HGV chassis, so that issue will be easily resolved for you I am sure.

 

What is not so clear is how these kind of specialist vehicles, Ferret and Saracen included, will be regarded if they are left completely out of any revision, as from what people are saying there seems to be no consist application of a clearly agreed / defined policy for them in terms of testing.

 

Hopefully the committee can be persuaded to look at this situation at the same time. Although given that their task is to sort out the non-tested HGV problem, it might not be possible for them to take the necessary action without a great deal more consultation between departments / bodies etc. For example it sounds simple to create a further vehicle classification or manipulate the MOT testing regime to accomodate our vehicles, but I dread to think of the discussion / consultation process they would have to go through to achieve this for us!

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( I was told by our local car MOT station this week that VOSA are tightening the MOT regs such that Tapley meters may possibly no longer permitted as the reading from the brake rollers have to be recorded as part of the test results and in view of this discussion I asked if this would apply to the HGV tests as well - he thought that it did - might be worth querying this ??).

 

New style Tapley... results can be recorded

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

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I'm getting a bit confused over this - the consultation document refers to "HGV Based vehicles" which I would take to mean anything that has it's basis in a vehicle designed from the get-go as a HGV or load carrier. This is not the case with the Stalwart - it came from the same base design that gave us the Saracen and Saladin. These preceded it into construction therefore it is manifestly NOT based on a HGV design, but is adapted from from an existing AFV design - same as the Salamander.

 

And if I am willing to take a (currently) taxed/insured vehicle to an approved MOT testing Station - but said station declines to test it because they cannot - where does that leave me and all the other Stalwart owners/ In fact - the Saladin and Saracen ones too as the same objections raised by the testing station apply- viz. they are not allowed to climb onto the vehicle to gain entry and have no facilities for the computerised testing of permanent 6 wheel drive vehicles ( I was told by our local car MOT station this week that VOSA are tightening the MOT regs such that Tapley meters may possibly no longer permitted as the reading from the brake rollers have to be recorded as part of the test results and in view of this discussion I asked if this would apply to the HGV tests as well - he thought that it did - might be worth querying this ??).

 

The problem is that in the consulatation document there are statements of intent, and arguements as to why certain classes will loose exemption.

 

The statements of intent and the justifications, all of which talk about HGV based goods vehicles, are not going to form part of the legislation. If the legislation merely removes ALL Locomotives and Light Tractors from exemption, then a whole load of vehicles that are not the intended taget group will be affected.

 

A blanket removal of exemptions, as proposed, will catch a lot of un-intended vehicles. We have no clue how the actual Bill will be worded. If you read the post that summarises my first conversation with Robert Newman you will find

 

"Quote"

Point 12 What Robert wants, is what we have started. Namely a list, decription of all the vehicle makes and models that will be difficult to test. He accepts the possiblity if there are a large enough number of cases of difficult vehicles to whole decision to proceed with the proposed changes might actually be abandoned. However if they go ahead he needs to know how to draft the legislation to include the target vehicles, but exclude the genuinely difficlut vehicles or those who will be finacially penalised for owning what are in effect Hobby vehicles.

 

Point 13 After the discussion period, ie after March 19th, there will be a meeting in London between Robert and MVT and FBVHC. Provisionally he has asked me whether I would like to attend. I plan to attend if at all possible. This is to try to come up with terms and definitions that ensure exemption remain for the correct vehicle types.

 

"Unquote

 

The task in hand is to define accurately the vehicles from which MOT exclusion is going to be removed.

 

We know what the intention is but "AS PROPOSED AT PRESENT THERE ARE NO STATEMENTS THAT WILL BRING ABOUT THE TARGETING OF GOODS VEHICLE BASED HGV'S, WITHOUT EVERYBODY BEING TARGETTED"

 

My mum used to say "good intentions are no good to anybody" meaning it is what you actually do that is important.

 

What is important is what the draft legislation says. and that we know will include differences from the consultation document.

 

Robert Newman said that he is working to arrive a t a form of words that will safeguard "the MAJORITY" of the non target group, but this may prove so complicated that "a small number of unintended vehicle MAY be affected by the changes"

 

Stalwart's position has not changed, in my opinion it has always been on dangerous ground. It is just becoming more evident that it will be very difficult to choose a form of words that includes Stalwarts in a group of MOT exempt vehicles and/ or allows legal use on the roads.

 

It is equally difficult to find a "Special Types" category for it to fit into for testing.

 

Why is it necessary to find a category within "Special Types" you may ask?

 

Every group within "Special Types" is exempted from different aspects of C and U regs. You cannot test a "Special types" vehicle without knowing which category it fits into, in order to no which C and U regs apply and which ones do not.

 

In my opinion Stalwart has no category to fit into.

Edited by antarmike
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I'm getting a bit confused over this - the consultation document refers to "HGV Based vehicles" which I would take to mean anything that has it's basis in a vehicle designed from the get-go as a HGV or load carrier. This is not the case with the Stalwart - it came from the same base design that gave us the Saracen and Saladin. These preceded it into construction therefore it is manifestly NOT based on a HGV design, but is adapted from from an existing AFV design - same as the Salamander.

 

And if I am willing to take a (currently) taxed/insured vehicle to an approved MOT testing Station - but said station declines to test it because they cannot - where does that leave me and all the other Stalwart owners/ In fact - the Saladin and Saracen ones too as the same objections raised by the testing station apply- viz. they are not allowed to climb onto the vehicle to gain entry and have no facilities for the computerised testing of permanent 6 wheel drive vehicles ( I was told by our local car MOT station this week that VOSA are tightening the MOT regs such that Tapley meters may possibly no longer permitted as the reading from the brake rollers have to be recorded as part of the test results and in view of this discussion I asked if this would apply to the HGV tests as well - he thought that it did - might be worth querying this ??).

 

 

Just my View.

I the Airport Crashtender Industry. vehicles are required to meet braking requirements, These vehicles

are permanent 4x4, 6x6, and 8x8 drive. as we well know it is not possible for these type of vehicles to be tested on brake rollers but never the less the vehicles still have to meet brake requirements.

For the airport crash tenders they have to comply to NFPA and ICAL regs. In order to obtain the brake % for the customer we use a digital brake meter. eg.http://www.wagerusa.com/media/brakemeters/brakecheck_leaflet.pdf

 

These are MOT appoved, and you can print out the test results.This is how the current BR90 bridging vehicles the MOD have where tested, due to the permanent 8x8 drive and tyres.

The big problem is that all the MOT test Stations have there own view and interpritation on the regs.

 

Clive

....................................

protruckservices.com

Edited by protruck
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That's a neat looking bit of kit!

Question is though Lee - will it hook directly into the system VOSA use for the automated MOT's these days. I assume here that the HGV MOT is required to have the same computer printed report as a car on - if not what follows is not relevant.

 

The blurb on the web site says:

Within the MOT centre this device is used as back up to the roller tester but used in principal on 4x4 vehicesl

and

this tester has a 99 test memory. Once tested the BrakeCheck can be downloaded to a PC through CabCheck software. this program can be supplied to print and store single tests or compile a database of results for analysis and reporting.

 

Which sounds to me like the results need to downloaded for the test and imported -somehow - into the VOSA system before the MOT certificate can be issued. Great if only doing one test a day but how many does a HGV test centre do? Can't see them being happy at the end of every odd-ball test having to go through the rigmarole of importing the data if there is a queue of commercial customers waiting to be checked. My local Class 7 station complained when they had to use the old Tapley on the Series 2A Safari we used to have. And complained even more when the tester concussed the little guy in the passenger seat watching it! :-\

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That's a neat looking bit of kit!

Question is though Lee - will it hook directly into the system VOSA use for the automated MOT's these days. I assume here that the HGV MOT is required to have the same computer printed report as a car on - if not what follows is not relevant.

 

The blurb on the web site says:

 

 

Also says...

 

BrakeCheck can be used and is accepted by VOSA for many vehicles, in the commercial sector VOSA approve BrakeCheck for testing all commercial type vehicles on every inspection.

 

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Another point re. brake testing:

 

When you present a HGV for testing it should be loaded to at least 50% (?) of its carrying capacity so that the brakes do not lock up when roller testing. This is because the examiner needs to establish how the brakes react under load. Turn up with no load and you'll get turned away.

 

So how on earth do they perform meaningful brakes tests on for example a 1968 6 wheel HGV operating empty with Historic tax? I presume they must assess the brake performance on the unladen condition weight only?

 

Which brings us back to the question of what criteria they are using to test these old vehicles!

Edited by N.O.S.
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Another point re. brake testing:

 

When you present a HGV for testing it should be loaded to at least 50% (?) of its carrying capacity so that the brakes do not lock up when roller testing. This is because the examiner needs to establish how the brakes react under load. Turn up with no load and you'll get turned away.

 

 

 

 

Tony,

Unless trailers are something different, then what you say about testing with at least 50% load is not true. Where I work from, the transport firms there run artics with flat and low loader trailers, when they go for test they are unladen, in fact one trailer usually has a load of timber blocks on as they do abnormal loads and the testing station will refuse to test with these blocks on board.

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Richard, I haven't taken a truck to the test centre since 1993 - so from what you say yes things might have changed!

 

On the other hand Adrian's post suggests that they might want the trailer unloaded so they can use the 'load applicator'.

 

I suspect bulk tippers - rigid and trailer - might need to take a load as it may be imnpossible to use the 'applicator' within these bodies?

 

HGV dealer workshops around here certainly used to keep loaded trailers with which to road-test tractor units and take for test - perhaps this was pre- load applicator days?

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In my opinion Stalwart has no category to fit into.

 

So the original question remains - what are we Stalwart owners supposed to do??

If they can't fit it into a class - and personally I believe it should be in with the Saracens and Saladin's as it is the same base platform to use the reasoning that seems to be behind this document - do we wind up with a whole lot of vehicles with a unique place in the history of Army transportation that can no longer legally turn a wheel?? After all - show rules say the Road act applies so no MOT cert must = no movement of Stalwarts. We end up with large lumps of steel that can never turn a wheel again, not even to drive on and off a low-loader.

Having just spent the best part of £15,000 getting mine back on the road again I am rather pee'd at the thought it might be wasted due to the whim of a civil servant from VOSA - a Gov't agency who have already cost me over £11,000 due to their incompetency!!!

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So the original question remains - what are we Stalwart owners supposed to do??

If they can't fit it into a class - and personally I believe it should be in with the Saracens and Saladin's as it is the same base platform to use the reasoning that seems to be behind this document - do we wind up with a whole lot of vehicles with a unique place in the history of Army transportation that can no longer legally turn a wheel?? After all - show rules say the Road act applies so no MOT cert must = no movement of Stalwarts. We end up with large lumps of steel that can never turn a wheel again, not even to drive on and off a low-loader.

Having just spent the best part of £15,000 getting mine back on the road again I am rather pee'd at the thought it might be wasted due to the whim of a civil servant from VOSA - a Gov't agency who have already cost me over £11,000 due to their incompetency!!!

 

PM sent.

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all - show rules say the Road act applies so no MOT cert must = no movement of Stalwarts

 

Incorrect, only certain parts of the RTA apply as show grounds are private property. No MOT or Road tax needed, vehicle has to have third party off road liability as a minimum & the driver must hold the appropriate licence for the class of vehicle driven... Vehicle must be in good mechanical order, so up to MOT standard where applicable...

 

Having just spent the best part of £15,000 getting mine back on the road again I am rather pee'd at the thought it might be wasted due to the whim of a civil servant from VOSA - a Gov't agency who have already cost me over £11,000 due to their incompetency!!!

Neil, comments like this are unhelpful when we have a man on here from the DfT who is trying to help us sort this mess out.

Edited by Marmite!!
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Incorrect, only certain parts of the RTA apply as show grounds are private property. No MOT or Road tax needed, vehicle has to have third party off road liability as a minimum & the driver must hold the appropriate licence for the class of vehicle driven... Vehicle must be in good mechanical order, so up to MOT standard where applicable...

 

 

Neil, comments like this are unhelpful when we have a man on here from the DfT who is trying to help us sort this mess out.

 

Sorry Lee - it's just that my experience with the organisations involved have been less than happy over the past year or so and coupled with this from the man representing the forums view:

 

Every group within "Special Types" is exempted from different aspects of C and U regs. You cannot test a "Special types" vehicle without knowing which category it fits into, in order to no which C and U regs apply and which ones do not.

 

In my opinion Stalwart has no category to fit into.

 

starts to get me seeing red as it reads to me like the Stalwart is being dismissed out of hand and could well wind up banned from the roads!! If I've misinterpreted what was said then I do offer my apologies.

 

If a Stalwart has "no category to fit into" it's because the civilian market never really had a niche for amphibious transports - I think BP were the only firm to experiment with them out East in the oil fields so thus has no bearing on UK regs. It's unique in that it's virtually the only wheeled load carrying platform the Army had that was not based on a civilian HGV - probably because no civilian derived vehicle was capable of earning and retaining the label of "High Mobility Load Carrier" through out it's service life.

I still maintain that if the premise of the consultation document is based on HGV derived vehicles then the Stalwart should belong to the same category as the rest of the FV-6xx family because that is what it is based on.

 

If the man from DfT can help resolve these issues so that none of us are unfairly penalised then I will be only too glad to review my opinion of these organizations upwards!

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Sorry Lee - it's just that my experience with the organisations involved have been less than happy over the past year or so and coupled with this from the man representing the forums view:

 

 

 

starts to get me seeing red as it reads to me like the Stalwart is being dismissed out of hand and could well wind up banned from the roads!! If I've misinterpreted what was said then I do offer my apologies.

 

If a Stalwart has "no category to fit into" it's because the civilian market never really had a niche for amphibious transports - I think BP were the only firm to experiment with them out East in the oil fields so thus has no bearing on UK regs. It's unique in that it's virtually the only wheeled load carrying platform the Army had that was not based on a civilian HGV - probably because no civilian derived vehicle was capable of earning and retaining the label of "High Mobility Load Carrier" through out it's service life.

I still maintain that if the premise of the consultation document is based on HGV derived vehicles then the Stalwart should belong to the same category as the rest of the FV-6xx family because that is what it is based on.

 

If the man from DfT can help resolve these issues so that none of us are unfairly penalised then I will be only too glad to review my opinion of these organizations upwards!

I have tried to keep this low profile by PM but if you can't keep your head down and it has to be spelled out on the board then so be it.

To repeat, whatever the situation of Stalwart, and I have only given my interpretation, the problems have not come from this consulation document, and this is no place for your anger.

 

I believe that Stalwart did not have a Construction and Use category, neither did it have a "special types" category to fit into at the time the C and U legislation was drawn up (1988) .

I am sorry to say but it is a case of "Caveat Emptor" Before deciding to buy something, it is up to the purchaser to decide if something is what he wants and if he can use it.

If I am right about the position of Stalwart, although "special types" legislation was re-draughted in 2003, in respect of Stalwart the categories are essentially the same as the 1979 legislation. I don't know when you bought your Stalwart, but certainly from 1979 onwards a reading of Construction and Use regs, and "Special Types General orders" should have made you aware that there was not a category into which Stalwart fitted.

 

You should have concidered your position before you bought.

 

However I am not saying you have no category to fit into, I am saying I cannot see a category for you which isn't the same.

 

I suggest you bite the bullet and write, with fullest details to DVLA and or VOSA , being honest about the width and the fact that it is constructed as a load carrier and ask them what your position is regarding this vehicle and ask for "a determination" You can do this before the end of the consultation process so then you will at least know your current position, We will have to see how the new act is worded to know if your position changes.

 

Mike.

 

The present process does not alter the situation that existed when you bought it.

Edited by antarmike
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