LEGISLATION & INTERESTING ITEMS
newsletters and articles below are produced by the FBHVC (The Federation of
British Historic Vehicle Clubs).
You can also view their website at www.fbhvc.co.uk.
Federation of British Historic Vehicle Clubs exists to uphold the freedom to use
old vehicles on the road. It does this by representing the interests of owners
of such vehicles to politicians, government officials, and legislators both in
UK and (through membership of Fédération Internationale des Véhicules Anciens)
FBHVC is a company limited by guarantee, registered number 3842316, and was founded in 1988.
There are nearly 500 subscriber organisations representing a total membership of over 250,000 in addition to individual and trade supporters. Details can be found at www.fbhvc.co.uk or sent on application to the secretary.
FBHVC –Newsletter №1 2012
HISTORIC VEHICLES MoT EXEMPTION REVIEW
The Department for Transport issued a consultation paper in November 2011 proposing as its preferred option a complete exemption from testing requirements for all pre-1960 vehicles, a far wider proposal than had been considered within FBHVC. Other options being considered by DfT were complete exemptions for all pre-1945 vehicles and all pre-1920 vehicles, or do nothing. The background to the discussions on the MoT test consultations has been well reported in previous newsletters.
The three month consultation period was inadequate for FBHVC to employ its usual method to gain feedback on these wider proposals. Consequently, it was decided to gauge the views of enthusiasts by means of an on-line survey and full details were given in the last newsletter, on the website, and to the press.
Over 4000 responses were gathered on-line. The survey enabled comment on the choice of cut-off date and at the time of going to press these comments are still being analysed, although it has been possible to broadly categorise these opinions. Those taking part were asked to indicate the age of vehicle they owned, and this piece of information will also be taken into account when the final analysis of the results has been made.
Summary of Results
· 74% of respondents wish to see testing requirements for historic vehicles relaxed.
· 59% support the government’s preferred option of exempting all pre-1960 vehicles.
· 71% believe historic vehicles in commercial use should be subject to testing even if other pre-1960 vehicles are exempted; 14% said commercial use should make no difference to testing requirements..
· 53% of respondents said they would take their vehicles for test if this could be done on a voluntary basis; 33% said they would not seek a voluntary test.
The opinions and reasons for them were qualified in many of the responses with conditional statements that the choice only applied if various conditions were met. Most common conditions were that there should be:
· no risk of restriction on use;
· no risk of increased insurance premiums for untested vehicles;
· no risk of insurers demanding (expensive) engineer’s reports;
· some facility for a formal standardised test to demonstrate roadworthiness.
The report will be published in full on the FBHVC website, www.fbhvc.co.uk, when the analysis has been completed.
In the last issue we indicated that we are seeking clarification from the DfT on aspects of the consultation, in particular on the ability to submit vehicles that fall inside the scope of any exemption to a voluntary test. The necessity for an MoT test is enshrined in other regulations: first registration on import; as part of the V765 procedure; obtaining an age related mark; transfer of marks; re-licensing from unlicensed etc. In all these circumstances a test is necessary for safety reasons and the prevention of fraud, and in the case of the import of vehicles never registered in the UK, conformity with Construction and Use regulations where the current Individual Vehicle Approval test would not be appropriate. We will be asking the Department for Transport to seriously consider this.
We are very grateful to all those who took part in the survey and also to Jim Whyman who did the analysis and administration while working to a very tight deadline.
By the time this newsletter is published, the analysis will have been completed and the board will have considered all feedback received before finalising FBHVC's response to the consultation.
There is a similar consultation taking place in Northern Ireland called: Proposal on Possible Exemption of Certain Categories of Historic Vehicles from MoT Testing. We will be sending a response to the Department of the Environment Road Safety and Vehicle Regulation Division to this consultation as well.
TRANSFORMING DVLA SERVICES
This consultation issued on 13 December was a Christmas present we could have done without – so could staff of DVLA Local Offices throughout the UK, who that morning were told that all LOs would close during 2013. This action will remove all face to face contact by the user public with DVLA staff.
Briefly, the DVLA stance is that the progress of computerisation needs to continue. To quote: ‘This means driving forward existing services such as increasing take up of driver services on-line. It also means making other transactions available electronically where this is cost effective and maximising uptake by making them as user friendly as possible’.
The consultation majors on increasing use of their existing vehicle licence transactions on-line (and telephone) services, but their (loaded) figures actually show that more than 50% of private users do not avail themselves of these facilities. Their so-called customer survey was based on on-line users only, ignoring the majority who do not, or cannot, use this facility for their transaction. There are vague promises to engage with ‘intermediaries’ but whether this is to provide computer access only, or a genuine replacement for end users with queries is also unclear. For individuals who are not computer literate are unlikely to use a DVLA provided facility.
The document then promises at some unspecified time in the future, to simplify other processes to enable additional transactions to be added to on-line facilities, no doubt on a cost effective basis. What they don’t mention are various transactions where we all, as old vehicle owners, necessarily have to go to our Local Office.
· Taxing an historic vehicle for the first time;
· Authentication of copy documentation for transmission to Swansea in lieu of valuable originals;
· Same day receipt of replacement tax discs for lost or stolen discs;
· Same day receipt of tax discs for taxing at short notice (including paper MoT and insurance cover notes);
· Taxing vehicles where there is also a change of taxation class e.g. unlicensed to historic, PSV to PLG;
· Taxing a vehicle exempt from MoT (I wonder how long Post Offices will be able do this?);
· Reinstatement of an original registration number where this had been replaced at some time in the past but has remained dormant;
· Inspection of vehicles which require an age related number or a chassis number;
· Inspection of imported vehicles requiring UK registration.
The FBHVC will be responding appropriately and remind all clubs and individuals that they may also send their own responses to this very important consultation. Hard copies of the consultation are available by writing to Corporate Affairs Directorate, D16, DVLA, Swansea, SA6 7JL. (The consultation did not provide a contact name or phone number.) Or www.dft.gov.uk/dvla then click on consultation. The consultation closes 6 March 2012.
Nigel Harrison has also written on some of the above points elsewhere in the newsletter.
A £4 BILLON HOBBY
That is the title of the report into the findings of our recent survey - and that is the economic value of our historic vehicle movement.
The work underpinning this result was undertaken in conjunction with the Historic Vehicle Research Institute over the summer of last year. Information was actually collected in four different surveys - clubs, museums, traders and individuals. The first three groups were asked about what they did, their annual turnover, their hopes and concerns for the future. Individuals were asked about the vehicles they owned, what they did with them, how much they spent and a little about themselves. This gave researchers information about both sides of the equation - what people spend, and what businesses receive.
The four sets of data were analysed during the autumn (this involved four large Excel work books, each with multiple worksheets, the largest of which had over 11,000 rows and 170 columns). The initial plan had been to announce the results in November, but finding that the River Room in the House of Lords would be available for a reception on 6 December, publication was delayed slightly to take advantage of this rather special venue, which is only available for such purposes by courtesy of the Lord Speaker.
Our president, Lord Montagu of Beaulieu, hosted the reception and Baroness D’Souza, the Lord Speaker, kindly welcomed our guests who came from both Houses of Parliament (many being members of the All Party Parliamentary Historic Vehicle Group, of which Lord Montagu is also president), the press, trade and academic contacts.
FBHVC vice president, Lord Steel of Aikwood, introduced proceedings. The headline research results were presented by the research project leader, Geoff Smith. These showed an encouraging situation:
Economic Value: £4.3 billion with nearly £1 billion from exports.
Average owners spend £2,900 on their hobby excluding vehicle purchase and restoration.
Employment: 28,000 working for some 3,800 businesses.
57% of specialist traders have been in business for over 20 years.
Vehicle Use: 0.24% of total vehicle miles with over 80% used no more than once a month.
There are over 850,000 pre-1981 vehicles in Britain.
Cultural Issues: Nearly 70% of vehicles are worth less than £10,000.
Over 30% of owners have a household income below £25,000.
59% of vehicle owners are in employment and 38% are retired.
Public Interest: 4.5 million attendances at FBHVC club events.
35% of historic vehicle owners perform voluntary work.
The Next Five Years: Over half of traders expect their turnover to grow.
Over 40% expect to recruit new or additional staff – approx.
66% of traders have concerns about business regulations.
68% of traders are concerned about regulations affecting vehicle usage.
This was followed by a question and answer session chaired by Greg Knight, chairman of APPHVG, with the research team of Dr Paul Frost, Dr Chris Hart, Dr Jaime Kaminski and Geoff Smith. Mike Penning, Parliamentary Secretary of State for Transport commented: ‘We have no plans whatsoever to restrict the use of classic and vintage vehicles - not as long as I am in my position. I see them as an important part of our national heritage’.
The research findings (which can be found in full at www.fbhvc.co.uk) show that the economic and employment record for the past five years and confidence for the future both buck the national trend, with the economic value of the movement having been at least been maintained in real terms despite the recent difficult trading conditions. It is excellent news that the number of people earning some of their living from the movement has increased by 1000 since 2006, and reassuring that traders are generally optimistic for the future, with many predicting growth, leading to more jobs. On the downside, many traders are concerned that the burden of regulations faced by small businesses may stifle this potential.
We are grateful to all the enthusiasts who completed the online survey, the traders, museums and clubs who returned the questionnaires. Additionally we owe our thanks to the research team without which this valuable information could not be obtained and to Jim Whyman who tirelessly did the analysis and administration.
Printed copies of the report have been sent to all club main contacts and to all traders and museums which responded to the survey. Further printed copies are available from the secretary at £5 each, including postage.
FBHVC –Newsletter №6 2011
HISTORIC VEHICLE MOT EXEMPTION REVIEW
As has been reported in recent Newsletters, the possibility of exempting certain groups of vehicles from the requirement to have an annual MoT has been under discussion since the end of 2010, with the expectation that there would be a consultation on the subject towards the end of this year.
The consultation was published at the beginning of November with the proposal that all pre-1960 vehicles should be excluded from MoT testing – this goes beyond the possible exemptions that had been mentioned in the Newsletter. We are seeking members’ opinions before responding, but time is short and the only practical way to get sufficient feedback to enable us to gauge members’ views is by means of an on-line survey, which will be on our website www.fbhvc.co.uk from early December to mid-January 2012. We ask all readers to alert as many historic vehicle owners and enthusiasts to this survey as possible by putting links on club websites, using e-circulation lists and so on. FBHVC cannot represent members’ views in the light of this wider proposal unless it knows what they are.
We have reproduced, below, the Introduction to the consultation in full (this sets out the legislative framework and DfT’s thinking), followed by a summary of the options being considered by DfT. We urge members to read the whole consultation on the DfT website: www.dft.gov.uk/consultations/dft-2011-27 as it is not possible to reproduce the entire text.
1.1 As part of the Reducing Regulation agenda and the desire to remove unnecessary burdens, the Government is proposing to exempt pre-1960 manufactured vehicles from statutory MoT test, as allowed under Article 4(2) of the EU Directive 2009/40/EC, and bring the age of vehicles requiring the statutory MoT test in line with The Goods Vehicles (Plating and Testing) Regulations 1988.
1.2 We consider vehicles manufactured prior to 1 January 1960 to be of historic interest. The purpose of this consultation is to invite views on proposals to exempt these vehicles from the statutory MoT test in GB.
1.3 Sections 45 to 48 of the Road Traffic Act 1988 provide the legislative basis for MoT testing. The purpose of the MoT test is to ensure that cars, other light vehicles (including some light goods vehicles), private buses and motorcycles over a prescribed age are checked at least once a year to see that they comply with key roadworthiness and environmental requirements in the Road Vehicle Construction and Use Regulations 1986 and the Road Vehicle Lighting Regulations 1989 (both as amended). A test certificate is issued following successful completion of an examination.
1.4 Whilst it is important to ensure that vehicles are safe to use on the highway, it is also important to ensure that regulations imposed are not excessive. Currently, both the age and the categories of vehicles requiring the MoT test in GB go further than the EU Directive on roadworthiness test 2009/40/EC, which only subjects post-1960 registered vehicles to a compulsory roadworthiness test and does not require motorcycles of any age to do a statutory roadworthiness test.
1.5 The EU Directive of the European Parliament and of the Council, Chapter II, Exceptions, Article 4 states: “Member States may, after consulting the Commission, exclude from the scope of this Directive, or subject to special provisions, certain vehicles operated or used in exceptional conditions and vehicles which are never, or hardly ever, used on public highways, including vehicles of historic interest which were manufactured before 1 January 1960 or which are temporarily withdrawn from circulation. Member States may, after consulting the Commission, set their own testing standards for vehicles considered to be of historic interest.”
1.6 The estimated 162,000 pre-1960 manufactured vehicles make up less than 0.5% of the approximately 32.7m licensed vehicles in GB that are required by law to have a MoT test. Two-thirds of pre-1960 manufactured vehicles are driven less than 500 miles a year.
1.7 Pre-1960 manufactured vehicles are largely well maintained by their owners. The initial MoT test failure rate for these vehicles in 2009 was less than 10%, whilst the initial MoT test failure rate for post-1960 manufactured vehicles was over 30%.
1.8 The Goods Vehicles (Plating and Testing) Regulations 1988 already exempts unladen pre-1960 manufactured Heavy Goods Vehicles (HGVs) from the roadworthiness test.
2 The proposals for consultation
[Option 0 Make no change]
Option 1 Exempt all pre-1960 manufactured vehicles from the statutory MoT test.
2 Exempt all pre-1945 manufactured vehicles from the statutory
MoT test, but continue to
demand that 1945-1959 vehicles are tested (unless already exempt).
3 Exempt all pre-1920 manufactured vehicles from the statutory
MoT test, but continue to
demand that 1920-1959 vehicles are tested (unless already exempt).
The consultation states that vehicles have not been separated by category or by use in the above options, so any exemption would include exemptions for, for instance, cars used for wedding hire and buses/coaches used for heritage tours.
Section VII of the ‘consultation-stage impact assessment’ that accompanies the consultation includes a statement that suggests that it will not be possible for any exempt vehicles to undergo a statutory MoT test on a voluntary basis.
We are seeking clarification from the DfT on certain aspects of the consultation, in particular on the ability to submit vehicles that fall inside the scope of any exemption to a voluntary test. This was originally an option agreed in principle by the DfT in talks earlier in the year but the extract from the impact assessment mentioned suggests this position has changed.
We value members’ opinion and urge everyone to read the DfT consultation and impact assessment www.dft.gov.uk/consultations/dft-2011-27 then go to the FBHVC website www.fbhvc.co.uk and complete the short MoT survey.
RED V5C ROLL OUT
DVLA introduced the new red V5C in August 2010. If there was a change made in the vehicle record, either for the vehicle or the keeper, a red front V5C was issued. From September 2011, when a vehicle is taxed or SORNed, DVLA will send the registered keeper the new red front V5C, if they have not already been issued with one. A DVLA leaflet, called ‘Your New, Red Front V5C (INS215)’, shown below will be included with the new V5C.
This leaflet states: ‘We [DVLA] will issue a new red front V5C for all vehicles by November 2012’. Although this is true for taxed and SORNed vehicles, DVLA have indicated that this is not the case for pre-SORN vehicles. A pre-SORN vehicle is one that was last taxed before 31 January 1998. Keepers of these vehicles also do not receive the renewal reminder for a tax disc or SORN (V11).
After November 2012, DVLA have indicated that they: ‘will be reviewing the pre-SORN records, to establish how best to issue red front V5Cs free of charge’ and will keep the FBHVC informed about how the ‘mop up’ exercise will happen.
If you wish to apply for a red front V5C before the free one arrives, you are likely to be charged £25. The DVLA recommendation is that registered keepers of pre-SORN vehicle do nothing at this stage.
FBHVC –Newsletter №5 2011
E-petition to restore a rolling 30 year old exemption to VED
On the face of it, this is an understandable move to eradicate the invidious gap between the VED treatment of pre-1973 vehicles and more modern classics, caused by the actions of Gordon Brown who, when Chancellor, stopped the rolling nature of the Historic VED category. The FBHVC have consistently asked for reinstatement on a thirty year basis (originally it was 25 years) but whilst Labour were in power it proved impossible.
Prior to the election last year the Conservatives acknowledged the anomaly and agreed to review it if they gained power, while warning that it would probably need to be fiscally neutral. (That’s before they opened the books!) The political climate (Coalition) and economic situation have deteriorated dramatically since the change of government. With the programme of deficit reduction adversely affecting government spending, including that for vulnerable sections of society, it is, in my personal view, the wrong time to raise the profile of this anomaly and could prejudice any future change for many years.
The theory behind e-petitions is that if the petition gets 100,000 signatures, and gets the support of the Backbenchers’ Committee, it will be debated in the Commons. It is inevitable that the coalition would be against change at this juncture since it cuts across the main government policy and would give away revenue to a minority interest. You can also imagine the reaction of the opposition; it would be perceived as giving away revenue to ‘Hooray Henrys’ in their expensive classics whilst at the same time cuts to expenditure on the NHS, Social Services, concessionary fares for OAPs and libraries continue. Issues raised in any debate would leave a lasting bad feeling against our movement and make it politically impossible to change the concession for many years. It is also possible that some opposition members might question the continuing existing concession. It is vitally important to retain public and political support for our movement and to avoid any accusations of being a blinkered self-interested minority. Adverse press coverage would be inevitable.
The FBHVC board will debate the merits of this petition at its next meeting on 21 September and no doubt it will also be a topic for discussion during the AGM.
STABILITY ADDITIVE TESTING
At the time of writing the testing of the additives is now halfway through the thirteen week programme. The results are expected in time for the AGM and Conference on 15 October – for details about tickets, see elsewhere in the newsletter.
The fuel used in the test is subjected to an ageing process at elevated temperature; it is recognised by the industry that 13 weeks’ ageing is equivalent to one year at normal temperatures and this is therefore believed by the petrol industry itself to give an accurate and representative account of the products tested. Those additives that pass the test will be entitled to carry the FBHVC’s endorsement – this means that they will protect against corrosion but it must be noted that there are currently no additives available that can protect against material incompatibility issues.
USE OF KEROSENE IN PETROL IN HISTORIC VEHICLES
Interest in adding kerosene to petrol for use in historic cars arose in the early 1990s after the disappearance of ‘two star’ leaded petrol. Some believed that higher octane four-star petrol could not be safely used in older low compression engines. This line of argument has been overturned, and in fact it is now generally accepted that while ‘excessive’ octane quality might be a waste of money, it is not harmful in low compression engines. The alternative view, that the greatly increased volatility of modern petrol is to blame for operating problems in older engines, is increasingly accepted. This aspect of modern fuels has been brought into focus again recently over the issue of addition of ethanol to petrol under the EU renewable fuels directive. Ethanol addition increases volatility, so any problems associated with high fuel volatility are not likely to be reduced with fuels containing ethanol.
With this in mind, there has been a renewal of interest in the addition of kerosene to petrol. Kerosene has a boiling range from about 160oC to about 250oC, whereas petrol boils over the approximate range 35oC to 195oC. Problems experienced in older engines, such as overheating, power loss, poor hot starting etc. have been attributed to the increased proportion of low boiling material added to petrol in more recent decades. This is believed to result in vapour formation in the wrong places, thereby upsetting fuel-air ratios, and in the main, causing enleanment of fuel-air mixtures reaching the combustion chamber. Addition of a high boiling material such as kerosene does not affect the ‘front end’ of the fuel in the sense of preventing low boiling-point hydrocarbons in the fuel from vaporising (low boiling point hydrocarbons in the fuel will boil off and form vapour long before the kerosene starts to boil), but if kerosene is added at 5% or 10% by volume for example, the proportion of the ‘front end’ components will be reduced by a corresponding amount, and this may be just enough in some engines to alleviate the negative effects of potentially excessive vapour formation. Some owners of historic vehicles report significant benefits from the use of kerosene in this way.
However, the main point about kerosene, which is its higher boiling range, should not be overlooked. The high ‘back end’ boiling temperatures associated with kerosene may result in incomplete combustion, since a fuel which has not completely evaporated will not burn. Any unburned material will find its way into the sump where it will dilute the lubricating oil. A significant amount of diluent derived from kerosene addition in the lubricating oil would run the risk of lubrication problems, with consequent increased wear of bearing surfaces. There has been some confusion over the use of kerosene blends in historic agricultural tractors, particularly as some of these used car-derived engines. However, in order for these machines to burn kerosene-blend fuels efficiently, a special vaporising inlet manifold was used on the tractor version, to ensure that complete combustion occurred, without the risk of oil dilution. The same engine in a passenger car, if operated on kerosene-blend fuels, will not be so well suited to these blends.
Kerosene addition is likely also to increase the risk of deposits in the fuel system, and may also increase the formation of sooty particulates in the exhaust gas. Overall, while it acknowledges that some historic vehicle owners have suffered from poor engine operation with modern petrol, the FBHVC does not feel able to recommend the use of kerosene in petrol in older vehicles. Instead, the Federation endorses the recommendations contained in a booklet published by the Vintage Sports Car Club, entitled ‘Fuel Problems – Use of Modern Petrol in Older Engines’ some years ago. These recommendations are felt to address the causes rather than the symptoms of the problem, and are still relevant today. The following suggestions are made in the report:
· adoption of local solutions to reduce heat input to the fuel system, principally from hot exhaust components
· use of insulating gaskets or other thermal breaks between fuel pump and engine and/or between carburettor(s) and inlet manifold
· use of heat shields to prevent heat being radiated from the exhaust system to the carburettor(s) and other fuel system components
· careful routing of fuel feed lines away from sources of heat en route from the tank to the carburettor(s)
These suggestions will be of most value in engines where the inlet manifold and the exhaust manifold lie on the same side of the engine. Engines where carburettors and exhaust are on opposite sides of the cylinder head tend to be much less affected by volatility related problems.
In addition, the condition of the radiator in water-cooled engines should not be overlooked. Old radiators can become really quite inefficient over time with accumulation of scale, debris and sludge on heat transfer surfaces, but the process can be slow and may not be noticed. Chemical flushing can improve cooling efficiency, but in some cases a replacement radiator core may be the best way to restore efficient operation.
EXEMPTION FROM VEHICLE TESTING
Goods vehicles over 3500kg Gross Vehicle Weight (GVW) first used before 1 January 1960, used unladen and not drawing a laden trailer are exempt from testing. This definition comes from the DVLA V112G form, called Goods Vehicle Testing – Declaration of Exemption (item 30). Some of these vehicles will have a ‘Ministry plate’.
Goods vehicles irrespective of their age which are 3500kg GVW or under will be subject to MoT testing. Where a vehicle has a Ministry plate, the GVW on that plate should be used to determine the type of test for that vehicle.
Where a commercial vehicle is close to 3500kg GVW, some owners may be unclear of the vehicle’s status. This is an area where specialist vehicle clubs may be able to offer assistance to owners and some publish a list of the vehicles that fall into their area of interest, indicting the GVW of each model, and if an MoT or Goods Vehicle Test is needed. As a general rule, for post-war non-military vehicles, if a vehicle has single rear wheels, its GVW is less than 3500kg, so the vehicle will be subject to an MoT.
One commonly used (or misused) testing exemption relates to breakdown vehicles. Exemption 3 on V112G reads as follows: ‘Breakdown Vehicles with permanently fixed lifting gear which are only used to lift and tow casualty vehicles’. The installation of a beaver tail does not in itself make it into a recovery vehicle that is exempt from testing, there is also the usage criterion in the exemption, which implies commercial use.
Another exemption relates to fire engines. Exemption 8 reads: ‘Vehicles designed and used solely for fire fighting or fire salvage purposes’. However fire engines registered before 1960 are treated as good vehicles and are exempt from testing.
REGISTERING COMMERCIAL VEHICLES
When a commercial vehicle is being registered, if the vehicle has a Gross Vehicle Weight (GVW) over 3500kg, there is a DVLA requirement to indicate the GVW on the V55/5 form (Registration of a used motor vehicle). It would be expected that specialist commercial vehicle clubs would have access to archive information which indicates GVW for each post-war model. With pre-war models, the information may not be available, and it may be necessary to resort to adding together the nominal payload of the vehicle to the unladen weight to give a GVW. VOSA have lists of design weights for goods vehicle from 1951, which is available if required. The contact is firstname.lastname@example.org
FBHVC – NEWSLETTER № 4, 2011
Exempting early vehicles from MoT
After the extensive article in the last newsletter about the possibility of exempting early vehicles from the MoT test there is little to report on the subject in this issue. The DfT are still engaged in an information gathering exercise in order to prepare both a risk assessment and impact assessment. A formal consultation is some way ahead (we believe this will not be before the end of the year at the earliest) and will require approval from the Minister and internal government procedural bodies before issue.
Changes to MoT testers' manual
EU Directive 2010/48/EU of 5 July 2010 updated directive 2009/40/EC that deals with the roadworthiness testing of motor vehicles. The purpose of the update, broadly, was to take account of technical advances in modern vehicle design and to improve consistency in testing standards across the EU. Its requirements are mandatory for member states which have to put in place all regulations necessary to comply with the directive by the end of this year.
This revision exercise does not set new standards for vehicle construction and use, but does increase the number of items that have to be tested. To meet the new requirements, the Vehicle and Operator Services Agency (VOSA), is having to revise the wording of the MoT testers' manual and it published its proposed amendments earlier this year in the form of a consultation that was described as a 'review of mandatory changes'.
All the concessions for older vehicles have been carried forward. In all there are 215 rewordings, changes and amendments to the existing manual. Unfortunately these amendments are scattered through the 218 pages of the draft document which has not helped to compile this précis.
Briefly the additional items are:
Inappropriate repairs/modification to brake systems, steering, suspension, tow bars;
Power steering fluid level;
Functionality of steering locks;
Coloured headlamp lenses which reduce performance of beam;
Operation of tell-tale headlamp warning light when fitted (for vehicles without this equipment a note accepts a date exemption);
Speedometer (Class 5 only);
Security of rear doors, locks and hinges;
Oil leaks from steering box etc;
Ball joint dust cover missing or damaged/insecure allowing ingress of dirt (ball joints which did not have protective covers are not required to be retrofitted);
Integrity of electrical wiring and battery;
Operation of electrical systems relating to anti-lock braking, stability control, supplementary restraint systems, together with associated warning lights;
Security and condition of towing structure – includes balls and pins;
Integrity of tow bar electrical connections – both 7 and 13 pin sockets (tested even if tow bar is missing);
Condition of engine mountings;
Front and rear drive shaft and gaiters – includes support bearings;
Driver’s seat adjustment (if there is any!).
In essence, if items are fitted they must be in good order, which should not raise concerns for responsible owners who maintain vehicles of any age.
One item we have picked up on, and have asked for clarification, concerns vehicles fitted new (or retrofitted) with high intensity discharge and LED headlamps. They will be required to be fitted with a headlamp washing system (wiper not required) and be self levelling. However the new text goes on to accept that some high performance vehicles fitted with HID that have limited luggage space and stiff suspension do not require a self levelling system.
It is envisaged that the final version will be available in January 2012.
THE CHEQUE LIVES ON
It has been announced that the plans to scrap cheques in 2018 have been abandoned. The Payments Council website made the following announcement:
The Payments Council is today (12 July 2011) announcing that cheques will continue for as long as customers need them and the target for possible closure of the cheque clearing in 2018 has been cancelled. The Payments Council Board will continue to focus on security, efficiency and encouraging innovation in all types of payments to ensure customers have options best suited to the 21st century.
Richard North, the Chairman of the Payments Council said:
"It's in the DNA of the Payments Council to consult and listen to all those people who actually make payments and use cheques. Listening to over 600 stakeholder groups, working with the banks and following our appearance before the Treasury Select Committee, we have concluded we should reassure customers that the cheque is staying.
“Over the last two years we have learnt a great deal about what is important to our many stakeholders and we are really grateful to all of those groups and individuals who took the time to talk to us and help us reach this decision. We will use what we’ve learnt to keep improving existing systems, as well as introducing innovation, so that customers benefit from 21st century ways to pay. Innovation must be at the heart of what we do.”
The Federation did campaign on behalf of members to keep cheques via the Federation of Small Businesses and the All Party Parliamentary Historic Vehicles Group.
Ethanol: Corrosion, Compatibility, and Combustion
There is still a great deal of misinformation being printed about ethanol in spite of some very detailed facts being freely available on our website. In response to members’ concerns we have distilled this information into three more easily digested paragraphs: Corrosion, Compatibility and Combustion.
Corrosion in fuel tanks and failure of traditional materials used in fuel systems due to incompatibility with ethanol may cause fuel leaks. Because fuel leaks create a high risk of fire or explosion, these matters have been given priority in extensive articles in the newsletter since October 2008. The articles show how the problems associated with corrosion and compatibility have been identified. As a consequence the FBHVC commissioned a test programme for commercial additives designed to overcome corrosion problems. Testing began in the second week of July 2011 and will take 13 weeks to complete in order to assess how well each additive responded to ethanol which will be progressively aged over the test period. Those products that pass the test will be entitled to carry the Federation’s endorsement. Some of the products are sold as corrosion inhibitors but contain other additives as well. This endorsement will be purely for the properties limiting corrosion, there will be no endorsement for valve seat recession or octane boosting properties which will not have formed part of the test.
There are no additives which can protect against other compatibility issues with seals and gaskets etc - there is a compatibility chart on our website where the details of suitable ethanol-resistant products can be found. Previously applied tank sealants, unless specifically designed for use with ethanol, are also likely to cause problems. Motorcycles with fibreglass tanks must check that the type of GRP used is compatible with ethanol.
Combustion, on the other hand, affects only the driveability of a vehicle and poses no significant risk to life or limb. Ethanol has long been recognised as a fuel supplement that improves performance and the FBHVC considers it unlikely that the modest proportions of ethanol in modern fuel will have anything other than a positive effect on the combustion process. Others, who take a different view, have criticised the FBHVC for not doing more to investigate the assertion that the presence of ethanol leads to slow combustion in low-compression engines resulting in poor performance, overheating and damage to exhaust valves. The Federation continues to investigate aspects of combustion with the aid of an independent consultant and the findings will be reported as soon as available.
Extract from FIVA’s regular update provided by its lobbying service, EPPA.
European Parliament Historic Vehicle Group
On 7 July, the MEP Historic Vehicle Group held another very constructive meeting in Strasbourg. FIVA led discussions on:
· Low Emission Zones and explained their impact on the use of historic vehicles. The Members agreed to help ensure that the European Commission is aware of the exemptions already in existence for historic vehicles for LEZs in Germany and Italy (all vehicles) and Denmark, Sweden, Hungary and the UK (HGVs) and to encourage the Commission to ensure that these positive precedents are included in the information they offer about LEZs to member states
· The cultural value of motoring heritage and the need for EU decision makers to recognise the importance and value of the work of the historic vehicle movement to the preservation of European motoring and cultural heritage. The Group recognised the benefits of developing a broad understanding of the cultural value of motoring heritage and agreed to help FIVA promote the message within the EU institutions.
Further details were discussed for the planned MEP visit to a historic vehicle museum in Brussels when it is also planned to hold an exhibition of historic vehicles and FIVA outside the European Parliament.
EU consultation on vehicle registration
In May, FIVA made a submission to a European Commission consultation on the registration of motor vehicles in which FIVA explained problems encountered when attempting to register a vehicle in another member state when an owner has no original, or incomplete, documentation of the vehicle. FIVA explained that this is not uncommon because of the passage of time and history of the vehicle since its manufacture; because it may have been restored from a barn find; or because the vehicle had never been registered because it was originally a military or similar vehicle. FIVA noted that in some cases, if a vehicle has no documentation, on importation it is treated as ‘new’ for registration purposes and stated that such action is not only inappropriate, but also results in practical problems and means that the vehicle does not benefit from being treated as a historic vehicle. FIVA went on to suggest that the situation can be avoided in future by:
· National registration authorities being willing and able to answer queries from registration authorities of other EU-countries within a reasonable timeframe to allow a swift resolution for the owner to questions concerning the registration documentation of a vehicle; and/or:
· authorities referring to available documented evidence of date of manufacture or documented evidence of first purchase in order to determine the age and details of the vehicle – FIVA made clear that such action would be consistent with a recent amendment to the Annex of Commission Regulation No 183/2011 defining a new vehicle which includes a footnote stating that: ‘In the absence of a registration document, the competent authority may refer to available documented evidence of date of manufacture or documented evidence of first purchase’.
European Commission consults of review of the Air Quality Directives
The European Commission has launched a review of the Air Quality Directives which are the stimulus for Low Emission Zones. The review is because the Commission feels that some measures are poorly implemented and limit values are regularly breeched and others, such as the national emission ceilings (NEC) directive, have expired or are due to shortly. Additionally, new scientific evidence has also emerged on the health and environmental effects of known pollutants and has raised new concerns arisen about others, including fine particulate matter and black carbon. The output of the review may lead to specific measures to address emissions from vehicles. FIVA will contribute to the consultation.
VOC Directive will not be broadened
The European Commission has decided against extending the 2004 paints directive to new products on the grounds that it would only deliver modest reductions in volatile organic compounds (VOC) emissions and could pose significant implementation problems. The conclusion followed a review of the existing Directive and an examination into its extension. It also concluded that there is no need to introduce stricter VOC limits for vehicle refinishing products.
Commercial Use of Historic Vehicles
At the end of the DVLA information sheet called ‘Notes about Taxation Classes’ (V355/1) is the definition for Historic Vehicles, which reads as follows. ‘All vehicles, except buses and good vehicles used commercially are exempt from vehicle tax if they were constructed before 1.1.73.’ See INF34, ‘Taxing Historic Vehicles’ for more information.
The key point is that if a pre-1973 bus or goods vehicle is being used commercially it should not have a taxation class of Historic Vehicle. A DVLA Local Office would be able to advise on the appropriate taxation class.
The MoT regime was introduced 50 years ago in the UK well before most of the EU states. Fromthe outset the UK test regime acknowledged the variations of specification and performance of older vehicles and has continued this approach on vehicles built subsequent to 1960, many of which are now the classic cars of today.
The Role of the Commission
The first Directive introduced the concept of testing but did not contain in specific detail methods of testing or minimum test standards/values. Other EU states often used the UK regime as a model when introducing testing (but not necessarily adopting the concept of variation for older vehicles). Recent Directives have majored on detailed procedures and minimum pass values which relate to the majority of the modern European car park i.e. incorporating testing of systems never fitted to old vehicles. Since new technology is constantly being incorporated in new cars, the testing regime has to keep pace with those changes.The EC has a system of technical committees, made up of permanent members together with representatives from member states to discuss and approve ‘technical changes’ to the fine print of Appendices to Directives (a Directive sets out principles, the Appendices the detail). This method of changing the technical detail without going through any consultation outside the civil service of both EU and member states is known as comitology.
In our case it would rely on the committee members from the majority of all participating countries having knowledge of our vehicles and taking into account our special needs, since any mistake in drafting could adversely affect our position. In general, the age profile of the ‘historic’ vehicle park in EU mainland states is biased towards post-war vehicles, (two major conflicts in Europe decimated the very old vehicles) and comparatively few before 1920, (as compared with UK) so committee members may not necessarily support the UK view. DfT staff are well aware of the need for continued vigilance, but in recent years FBHVC has had to prompt action in some areas. Like all employers, corporate memory is confined to fewer people and in practice only goes back 40 years – our vehicles go back 125! Other factors are that the EC is keen on majority voting, has a dislike of permanent continuing exemptions, and sometimes forgets the principle of no-retrospection that was one of the first things that was agreed in principle when FBHVC was established in 1988. Since the UK old vehicle park is the largest and most varied in Europe we are more at risk.
The physical test in UK Testing equipment has become more sophisticated and continues to be developed to eliminate use of discretion by the tester. An example is computerised headlamp equipment that uses a back screen with imbedded light sensors to measure headlamp beams. This machine is placed appropriately in front of the headlamp, the tester then presses a start button, the machine runs its course and then illuminates a green or red light. The machine makes at least two assumptions 1) there is a focussed beam; and 2) there is no scatter. It is currently being introduced /used for testing commercial vehicles and would be totally unsuitable for most vehicles right up to the eighties. Shaking plates are increasing in use to check suspension defects but it has to be said that most time served testers still rely on the bar! Over the years brake rollers have replaced the old decelerometer (Tapley meter to you and me) and there have been reports of resistance by testers to use the old method on older vehicles, despite the unsuitability of rollers for very old cars or those fitted with solid tyres, mechanical transmission braking etc. The IT system used by VOSA does not show the tester all the concessions/exemptions which are allowable for the actual vehicle tested. It was obviously designed for modern vehicles only (one size fits all!) and unfortunately some owners are less than diplomatic in the way they point these failings out to younger testers. This attitude does not make the tester sympathetic to subsequent old car owners!
GaragesOne big concern is that the trend away from small independent garages will lead to loss of essential testing expertise. Small, independent operators are under pressure and this sector has diminished over the last ten years. The motor manufactures have all contracted their dealer networks and virtually abolished agencies to concentrate on (in the main) dealer networks owned by large groups.
The selling of fuel has also drifted away to larger chains and supermarkets and since the smaller outlets cannot possibly compete on price this move will have adversely affected the profitability of smaller concerns. The main dealers owned by large groups compete on price for servicing and many offer free MoTs. There is also the inevitable loss of small family owned garages due to retirement and the lack of interest by the next generation. Whereas five to ten years ago finance was available at variable cost, in recent years and into the immediate future getting finance to purchase is problematical. I also understand that on change of ownership VOSA makes it mandatory that test equipment is upgraded. I am aware that small garages are unhappy with the trade organisations that are supposed to represent them, which have become dominated by personnel from large groups. It is interesting to report that a
few years ago, when the trade bodies were lobbying for an increase in MoT fees to cover additional test items, I cheekily suggested a reduced fee for old vehicles, since they didn’t have these and other features. The trade reply was that testing of old vehicles took longer because testers were unfamiliar with exemptions and had to look them up!For these reasons the FBHVC has launched a section on its website to collate recommendations from clubs of MoT testing stations that are happy to deal with our small section of the UK vehicle park. Like Post Offices, small garages will die if they do not receive regular custom – not just for your MoT. It should be remembered that the MoT test only proves that a vehicle complied with Minimum Test Standards at the time of the test. We understand that it is perfectly possible to enter a vehicle for a test at any time without there being a legal requirement to do so – but if the vehicle fails it is unroadworthy and should not be used.
VEHICLE HEIGHTS AND LOW BRIDGES
This item is relevant to buses, trucks, vans and caravans. We recently received details of a meeting held to discuss bridge strikes, attended by Network Rail, the Highways Agency and others. The 1986 Construction and Use Regulations stipulate that for a vehicle over three metres high, the height must be displayed in the cab - in the case of a towing vehicle this may be a device that allows a different height to be selected depending on the height of the trailer being towed. Many vehicles built before 1986 will have the height displayed in the cab, however for those which do not, we recommend a simple sign inside the cab be added, in order to aid both regular and occasional drivers of your vehicle. We would also urge drivers who tow a caravan or trailer to write the height somewhere easily visible from the driver’s seat (even if just on a piece of paper stuck to the headlining), even if the trailer is below three metres (9'10").
We would also politely remind drivers that overhanging branches can do damage to your prized vehicle and urge all drivers to keep a careful eye out, especially when on a road that isn't regularly used by double decker buses. Low bridges or overhanging trees are a particular hazard when one is following a satnav, or following the directions of someone unfamiliar with high vehicles.In general, bridges with a clear height of five metres (16'6") or less are required to be signed with their height. Should you be aware of a bridge locally to you that is missing its sign on one side or the other(or in your opinion is insufficiently signed) please report this to the council with responsibility for highways. Likewise, if you know of a road with overhanging trees, this should also be reported to theauthority, who have a statutory duty to coordinate landowners trimming trees on their own property,and council staff trimming trees located on the highway. It would be appreciated if all member clubs, including those dealing solely with cars, could include the paragraph above in their newsletter, in order to help vintage commercial preservationists.
In the last issue of the Newsletter we printed extracts from the long-awaited QinetiQ report on theeffects of bio-fuel on older vehicles. As a result of FBHVC involvement there are signs of a softening of government attitude to allow the supply of E5 fuel until at least 2015 and there is a suggestion of provision of low ethanol (whatever that is) fuel for historic vehicles. It should be remembered however that our vehicles use a very small percentage of the total UK fuel sales and it may be difficult for retailers to commercially justify stocking such fuel even if the oil companies will distribute it. The Federation will continue to monitor the situation and are working with the All Party Parliamentary Historic Vehicle Group to see what can be done.In 2010, through our trade supporter scheme, we introduced five companies to a manufacturer of a corrosion inhibitor additive for petrol. This additive should overcome many of the problems associated with the inclusion of ethanol in petrol (but not material compatibility issues, please note). One of these companies, Tetraboost, who also supply an additive for unleaded petrol, have sent us the following statement about the launch of the product in the UK. ‘TetraBOOST E-Guard™ has been specially formulated to give protection from potential damage caused by ethanol in petrol, except for GRP tanks and sealants. In addition it will prevent deterioration of fuel kept in a vehicle tank for several months during winter. It will be submitted to the FBHVC for testing as soon as they have the facilities prepared. The problems with ethanol have been fully explained in earlier FBHVC Newsletters and on their website. TetraBOOST E-Guard™ will be supplied through retail outlets, dealing with automobile parts and accessories, in 250ml bottles sufficient for 250 litres of fuel. It will not be available direct. However, as stockists are appointed, they will be listed on the Tetraboost website www.tetraboost.com.’The Federation hope to have the test programme up and running very soon; there have been some technical problems to overcome but we are hopeful that later this year we will be able to offer an endorsement to the products that pass the test regime.