Statement from FBHVC
We have been in discussions with DfT during the drafting of this Government Response to Consultation and have made a number of suggestions.
We always knew that when it came to the detail of implementing the Directive the difficult task would be complying with the obligation to exclude substantially changed historic vehicles from roadworthiness testing. The challenge for DfT has been in defining “substantial change”, on which the Directive gives no guidance,
During our discussions with them they have tabled various formulae but because of their prescriptive nature and the shear diversity of the UK’s historic vehicle parc, we have always been able to point to vehicle groups which due to their characteristics would be regarded as “substantially modified” even though they were considered by marque experts to be historically interesting. One example of this phenomenon would be Austin 7 Specials or indeed the Ford and BMC derived specials of the 1950’s.
This difficulty is presumably the reason why DfT have chosen to publish their current thinking on this definition as a separate “Draft Guidance” document with the specific caveat that it is still subject to further discussion with stakeholders (specifically FBHVC, and indeed DfT have told us that we will be having further meetings on this issue).
We are encouraged to pursue this process by the evidence in the current draft that several of our concerns and suggestions have been addressed. For example adopting the 1988 cut-off date prior to which modifications are discounted clearly addresses the “in period specials” issue.
There are still issues to be addressed if we are fully to represent the wide interests of our members, not least of these being the adoption of a power to weight criterion in the Draft Guidance. We are unsure as to what type of vehicle this exclusion is aimed at trapping. However what is clear is that the adoption of the rather modest 15% uplift threshold would capture a great many vehicles which in period would have been offered with standard power unit options exceeding by some margin these tight limits.
In addition we were led to believe that declaration of modification to a vehicle would be a voluntary process whereas it appears from the process that is outlined in the DfT document not to be the case.
We are getting a great deal of feedback from members on our Facebook page (10,000 hits in two days!) and we would be pleased to hear from any member clubs who have an issue with any part of this Government response.