latest dvla problem

[mike65]

You will probably find they are working on all fronts to keep any inappropriate vehicles off the road and sadly this makes it harder for those who have unusual, nut compliant vehicles amd those who legitimately and permanantly modify vehicles to make them compliant.

I am aware that VOSA and DVLA have been clamping down on strecth limos many of which are non-compliant.

I am aware thart C&U regulations dictate that HGVs have to be able to turn within an inner and outer radius range, meaning they can negotiate most roundabouts. I remeber an enteryaining 5 minutes watching a stretched limo (SUV job) trying to to a 180 degree turn on a roundabout. I t involved a 3 point turn using both footways infront and behind.

They also need to clamp down on legitimate venicles that have been modified and are no longer compliant, but that is another issue.

 

Mike

[N.O.S.]

As I intimated back in post 126 (of course I was a lot younger then) -

 

1) find out what secondary system(s) the vehicle has,

2) find out what the specific requirement of a secondary system are,

3) find out if your secondary system meets these requirements - if so then

4) obtain proper evidence of the compatbility, and finally

5) present the case to DVLA in a way in whiich they are bound to accept the evidence.

 

From the information presented in this thread so far, next stage to tackle seems to be 2)!

 

The fact that DVLA are talking with MOD should be seen as a positive move.

[Marmite!!]

Copies of the info received below.. I'm asking them for full copies of the emails now..

 

[N.O.S.]

This seems a very fair and sensible approach, one which is very difficult to reason against. Clearly it is the applicant's responsibilty to demonstrate compliance.

 

The fact that MOD states the vehicles do not comply with C&U secondary braking requirements dos not mean there might not exist a practical solution - who knows, maybe as simple as inserting a valve in a brake line, like repositioning a light unit!

 

Since I know nothing about either braking systems on these modernish tracked mvs, or C&U braking regs I cannot offer any advice, other than to recommend (from experience) this company - who might just be able to offer the solution you are seeking:

 

www.erentek.co.uk

[ArtistsRifles]

Out of curiosity - I believe Alvis no longer exist as such - so how can the owner contact the now non-existent manufacturer???

[griff66]

buyer beware after 2014 for heavy mvs under 25 years old!

[Richard Farrant]

Out of curiosity - I believe Alvis no longer exist as such - so how can the owner contact the now non-existent manufacturer???

 

 

Alvis no longer exists in name, but I think you will find that there is a responsable company to cover there products still in service worldwide, and my guess is it would be BAE Systems.

[N.O.S.]

Out of curiosity - I believe Alvis no longer exist as such - so how can the owner contact the now non-existent manufacturer???

 

DVLA only cite the manufacturer as an example of a suitable source of evidence. Any qualified engineering consultant with the appropriate knowledge of braking systems and C&U regulations could provide this evidence.

:idea:

[ArtistsRifles]

Alvis no longer exists in name, but I think you will find that there is a responsable company to cover there products still in service worldwide, and my guess is it would be BAE Systems.

 

DVLA only cite the manufacturer as an example of a suitable source of evidence. Any qualified engineering consultant with the appropriate knowledge of braking systems and C&U regulations could provide this evidence.

:idea:

 

 

Thanks for th clarification folks. Especially the bit about an independent expert. I always found getting info out of BAE was like getting blood out of a stone...

[ChasSomT.]

Out of interest, what ARE the C + U secondary braking requirements?

It has always 'bemused' me that for an ordinary car 'MOT' the handbrake is tested as a secondary braking system, when in a lot of cases, it has been designed solely as a Parking brake.

Chas.

[antarmike]

Out of interest, what ARE the C + U secondary braking requirements?

It has always 'bemused' me that for an ordinary car 'MOT' the handbrake is tested as a secondary braking system, when in a lot of cases, it has been designed solely as a Parking brake.

Chas.

Secondary braking is normally a totally independant system to slow the vehicle from speed if the normal service braking system fails. Whether C and U define Secondary braking in this sort of way I do not know.

 

Amongst systems normally regarded as seconadry braking (electromagnetic retarders, Voith, Jake brake etc,), the most common secondary braking system, as it applies to HGV,s and the like is the Spring brake chamber.

 

The brakes are normally controlled by air pressure, but if the air pressure system fails, the brakes will be applied by spring pressure, totally independently of the air system.

 

On older vehicles the Secondary braking system was by dual diaphragm Brake chambers, and two air tanks, one fed from the other through Circuit protection valves. The normal service brake is fed via the foot valve from one, and this applies air to one diaphragm, a hand valve applies air from the second tank to the other diaphragm, should the foot valve, or its associated air tank fail. (on trailers the secondary brake chambers used to be operated via the Blue Auxiliary suzie.)

 

A transmission brake is not normally considered secondary braking, because it is not designed to be used at speed

 

How are the service brakes of Stormer applied? Is it air pressure or good old hydraulics (brake fluid). If it is by air, does it have spring brake chambers and an inverse foot valve, or is it air operated by direct proportional air pressure?

Edited November 21, 2010 by antarmike

[mike65]

So it looks like it not an outright no its a case of prooving it meets the requirements.

Now the problem is working out what they are and what they mean in real terms.

I notice you cannot get the C&U online (at least I cannot find it) or the nice leagal document that cost £1K. O wonder if the local library has a copy?

Have found a load of amendments though

http://www.legislation.gov.uk/title/road%20vehicles%20%28construction%20and%20use%29%20regulations?level=search

Have found this though. I believe it is the document set up for the SVA testing of imports and kit cars.

http://www.legislation.gov.uk/uksi/1996/3013/made

.

 

Mike

[Sidewinder]

Just wondering, and maybe I am being a bit niave, but could it be worth writing a polite letter to the Secretary of State (Theresa May? As if I understand correctly she has the power to grant exemptions?) explaining the situation that essentially we are a responsible hobby, who get a lot of joy from our vehicles and in turn give a lot back to the general public in the form of shows, events and fundraising etc. That mostly we do very little mileage on the road (as previously stated not many people would be willing to take tracked armour on much more than a 10 mile round trip) perhaps a few times a year. And that we maintain and restore our vehicles to very high standard and would represent a tiny percentage of total road traffic, of whom, judging by what I saw on my 60 miles of motorway driving tonight, mostly don't deserve to ride a push-bike let alone be allowed a driving licence! Although maybe miss that last bit out! But you get the idea, just generally putting across our message as has been stating in previous posts..

 

James

[antarmike]

Just wondering, and maybe I am being a bit niave, but could it be worth writing a polite letter to the Secretary of State (Theresa May? As if I understand correctly she has the power to grant exemptions?) explaining the situation that essentially we are a responsible hobby, who get a lot of joy from our vehicles and in turn give a lot back to the general public in the form of shows, events and fundraising etc. That mostly we do very little mileage on the road (as previously stated not many people would be willing to take tracked armour on much more than a 10 mile round trip) perhaps a few times a year. And that we maintain and restore our vehicles to very high standard and would represent a tiny percentage of total road traffic, of whom, judging by what I saw on my 60 miles of motorway driving tonight, mostly don't deserve to ride a push-bike let alone be allowed a driving licence! Although maybe miss that last bit out! But you get the idea, just generally putting across our message as has been stating in previous posts..

 

James

She has the power to grant exemption to operated military vehicles. ie those under control of the state. she also has the power to grant exemption to exceptionally wide loads ( i.e. those over 4.3 m.). She is only empowered to grant these limited exemptions. She does not have the power to grant exemption to privately owned ex Military vehicles.

 

The way forward has to be IVA . Everybody is saying so, so maybe instead of going round and round the same erroneous arguments, why not just take it for IVA inspection and see what happens ,,,,

Edited November 21, 2010 by antarmike

[antarmike]

To quote the Freedom of Information disclosures

" The most logical route to approval for relevant vehicles would be the IVA inspection scheme offered by VOSA. This will eliminate the need for DVLA to attempt to gauge whether the vehicle complies with legal requirements as VOSA would be testing the vehicle to check this."

 

Straightforward, sensible advice, why try to do other than the suggested solution offered by VOSA?

[ArtistsRifles]

To quote the Freedom of Information disclosures

" The most logical route to approval for relevant vehicles would be the IVA inspection scheme offered by VOSA. This will eliminate the need for DVLA to attempt to gauge whether the vehicle complies with legal requirements as VOSA would be testing the vehicle to check this."

 

Straightforward, sensible advice, why try to do other than the suggested solution offered by VOSA?

 

Possibly one reason might be that anything originating from VOSA needs to looked at under a microscope from both sides - preferably by a lawyer.

 

What ever the organization may issue could well be with the best intent - but experience here on HMVF and elsewhere on other forums seems to reveal a disconcerting lack of knowledge amongst it's operatives in the field. Thus if VOSA operatives conduct the IVA then there are grounds to fear that the result might be subject to personal opinions and not the spirit/letter of the regulations.

If the IVA were to be carried out by trained and qualified independent companies then there would be greater trust in their findings.

[cosrec]

[quote Thus if VOSA operatives conduct the IVA then there are grounds to fear that the result might be subject to personal opinions and not the spirit/letter of the regulations.

Quite right the same as the person taking the vehicle have their own personnal opinions. Remember you can appeal if it fails, But to sum up up if it dont comply with C&U regs it fails

[antarmike]

Possibly one reason might be that anything originating from VOSA needs to looked at under a microscope from both sides - preferably by a lawyer.

 

What ever the organization may issue could well be with the best intent - but experience here on HMVF and elsewhere on other forums seems to reveal a disconcerting lack of knowledge amongst it's operatives in the field. Thus if VOSA operatives conduct the IVA then there are grounds to fear that the result might be subject to personal opinions and not the spirit/letter of the regulations.

If the IVA were to be carried out by trained and qualified independent companies then there would be greater trust in their findings.

 

If an independent engineer inspected this Stormer and found it did meet requirements, and this conclusion went off to DVLA, they would then have two reports, one from the army saying it doesn't comply and one from an engineer saying it does. DVLA have said they cannot be in a position where they have to decide whether it comlpies or not, and that is exactly what they would then have to do, since they now have two pieces of paper with contradictory content, and they would have to decide which to accept.

 

They have said they will accept VOSA IVA.

 

My advice is still, forget independant engineers, do as they ask and go for an IVA.

[N.O.S.]

Each to his /her own, but I would not dream of turning up to a VOSA IVA without first having established what conditions the vehicle has to meet - not just the cost but it doesn't convey the right impression to the inspectors (wouldn't it irritate you if someone turned up to your mot test station unprepared?).

 

Knowing there could be an issue with secondary braking, I would first contact VOSA to establish what is expected of a secondary system on this type of vehicle (perhaps try making an appointment / calling at the local test station to talk through the issue with the guys who would be inspecting it?). I suspect the requirements might not be the same as a car or HGV.

 

I understand that handbrakes, when accepted as a secondary brake, may have to meet a performance standard (e.g. around 50% of the peformance of the service braking system?) - you never know, simply installing a power servo system (air or spring chamber) on the handbrake system may be sufficient to allow the vehicle to comply :-)

[xtreme]

IVA is more than C&U Its hard enough to get a new 2010 american import through never mind a MV . Sharp edges and headrests is just one thing that will fail.

 

A 10 year old vehicle imported into the UK is except from IVA so why should a over 10 year old UK vehicle have to go through it .

 

Lighting regs is easy and its clear theres 2 separate braking systems on the cvrt range anyone that has owned one knows it.

 

Anyone know an engineer willing to write a report

[ArtistsRifles]

You could try contacing BAE and asking if they will confirm the type and nature of the braking system - they should still have the Alvis records and design details on file. Might take a while to get an answer though - or it might not now - when I worked on a CAE project a few years ago or them comms were the biggest problem.

[N.O.S.]

IVA is more than C&U Its hard enough to get a new 2010 american import through never mind a MV . Sharp edges and headrests is just one thing that will fail.

 

A 10 year old vehicle imported into the UK is except from IVA so why should a over 10 year old UK vehicle have to go through it .

 

.......

 

Well if it doesn't require an IVA, other than to establish the presence of a secondary brake system and compliance with lighting, try asking DVLA if they will accept an inspection report from VOSA on just the braking and lighting systems. And ask VOSA if they will conduct a partial IVA on just these points. May cost you a full IVA fee though, but could be best way to satisfy DVLA :cool2:

[Stone]

So it looks like it not an outright no its a case of prooving it meets the requirements.

Now the problem is working out what they are and what they mean in real terms.

I notice you cannot get the C&U online (at least I cannot find it) or the nice leagal document that cost £1K. O wonder if the local library has a copy?

 

You can get a copy of C&U 1986 from The Stationery Office - in fact given that I think this is the only place where you can get it, £26 doesn't seem at all bad!

 

link

 

I've mislaid my copy but it's very useful so you can tell what the basic pre-amendment spec is/was. You can't get an 'as amended' version anywhere except as interpreted by the legal textbooks previously mentioned, but it's very easy to just do your own research.

 

If the Stormer has the right kind of braking system as described in C&U then your first recourse is to write to the DVLA and say so. I'm sure photocopies of the relevant manuals would illustrate the point adequately - bearing in mind you will need to remove all ambiguity by saying '(1) in the attached diagram shows the service brake shoes, (2) is the separate steering brake, (3) is the parking brake' etc. Refute their points one by one and if it meets the regs you will be able to register it. If you need to modify it to meet the regs then do so, and tell them what you've done to make it comply. Personally I'd be most worried about elements you can't do anything about (width, viewing angles) than stuff you can.

 

BAE won't help you unless you're under contract with them, or you happen to find the single employee in the right department who's interested in MVs and wants to help. Why would they when all the info is available to do it yourself?

 

Stone

[Marmite!!]

You could get VOSA to carry out a Voluntary Brake Test, if it passes then that should be good enough for the DVLA..

 

http://www.vosa.gov.uk/vosa/repository/Preparing%20Your%20HGV%20for%20Brake%20Test%20-%20Best%20Practice.pdf

 

 

VOSA voluntary brake testing

Voluntary brake testing is a service provided at

VOSA test stations. For a small fee, VOSA will

conduct a standard brake test, and this will

highlight any areas for concern in the braking

system(s).

Other advice

Secondary braking systems

Vehicles are fitted with a secondary brake,

typically either through a split braking system,

or a progressively applied hand control valve.

Make sure you know which type your vehicle

has, and if the other system can be used as an alternative.

 

 

[antarmike]

IVA is more than C&U Its hard enough to get a new 2010 american import through never mind a MV . Sharp edges and headrests is just one thing that will fail.

 

A 10 year old vehicle imported into the UK is except from IVA so why should a over 10 year old UK vehicle have to go through it .

 

Lighting regs is easy and its clear theres 2 separate braking systems on the cvrt range anyone that has owned one knows it.

 

Anyone know an engineer willing to write a report

 

Is the second braking system designed to slow the vehicle at speed, or is just for parking? A vehicle can have a system for a handbrake, that is unsuitable for bringing the vehicle to rest from full speed. I understand a secondary braking system to be more than just a handbrake. On the service brake, if it were to fail, how can the vehicle be stopped from full speed?

 

Is the service brake air operated, air over hydraulic, servo hydraulic or what. If it is air operated or air over hydraulic would total loss of air pressure in the primary reserve, cause the vehicle brakes to come on? Is there a second air tank, protected with a circuit protection valve, and a second brake vlave (i.e. one that is progressive and offers accurate control of the applied braking) run from this. Can anyone decribe, beyond where the brake shoes, calipers work, what actually comes before them, Ie what is between the brake pedal and the friction material?

 

What percentage of service brake efficiency can be achieved by the secondary braking sysytem?

Edited November 22, 2010 by antarmike