28 JUNE 2006
Those present: David Hurley (in the chair); Jacqueline Bickerstaff; David Davies; Sandy Hamilton; Rosy Pugh, Geoff Smith, Jim Whyman (secretary).
Apologies for absence: John Billard; Andrew Burt; Peter Henley; Peter Mead and Matt Vincent.
1. Minutes of the meeting of 26 April 2006After correcting a typing error, the minutes of the meeting of 26 April were signed as accurate.
2. Matters arising not included on the agenda
None.
3. UK Legislative Matters
A. Post consultation position reports:
a. Measures to enforce insurance “from the record” No further news.
b. Improving access to public transport for the disabled David Hurley reminded the meeting that Greg Knight had submitted a question on this subject to the minister responsible, receiving a response that related only to railways. The minister concerned had subsequently departed, but Greg had written to her successor. David commented that the disabled groups he had been in touch with were reluctant to put anything in writing, but had confirmed verbally that they would raise no objection to an exemption for “heritage” services.
c. Transposing EU Directive 2004/42/CE (VOC) into UK law The secretary said that Ian Oldfield of DEFRA had been in touch to confirm that DEFRA would be producing regulations allowing the sale under licence of non-compliant products.
d. MoT testing for fire appliances
David Hurley said he had only recently received the full minutes of the meeting at DVLA that he had referred to at the previous meeting and so had not had time to prepare notes to circulate. Fire appliances not used solely for fire fighting purposes were no longer exempt from testing, and so must be plated and tested as goods vehicles. However, fire appliances were (and are still) exempted from type approval. Because of this they were not covered by The Road Vehicle (Construction & Use) Regulations 1986, which under regulation 15 made European standard braking systems mandatory for all goods vehicles. Instead appliance manufacturers could equip machines with braking systems complying with the Home Office Joint Committee on Design and Development (JCDD) standard. So whilst front line machines can be used with brakes that obviously work, as soon as they are sold they become illegal. The problem is that VOSA is proposing to test fire appliances as goods vehicles, which they are not: they need to be tested as they were designed, built and operated. David Hurley said he would be discussing the problem further with VOSA. DHe. Waste framework directive The secretary said a summary of responses to the consultation had now appeared on the DEFRA website. This mentioned FBHVC’s request that nothing should be done to prevent farmers storing obsolete machinery. There was no indication of how any new regulations might be worded.
f. Compulsory seat belt requirements for children No further news.
g. Testing requirements for new drivers of large vehicles David Hurley said he had followed up the response to the consultation with those concerned and said he had been given an unofficial assurance that those who were only likely to drive preserved historic vehicles would escape the full brunt of the new requirements – they would only have to pass the theory test and the practical, but not the modules for the Certificate of Professional Competence.
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- 2 -3. UK Legislative Matters (contd)
h. Operator Licensing consultation David Hurley said he had also spoken to the civil servant looking after this consultation and had been told that FBHVC members were unlikely to have anything to worry about.
j. release of vehicle data from the record No further news.
k. low emission zone proposals for London David Hurley said the LEZ team had been grateful for the statistical information provided by FBHVC and it was understood that this team was designing a system that would take the concerns into account. The team leader had changed, and David said he was being kept informed of progress.
l. Highway Code The secretary said a response to the consultation had been submitted as agreed at the previous meeting. This had been acknowledged, and it was likely that several of the points raised might be incorporated, including the reference to the code for drivers of older vehicles.m. implementing EU Directive on sulphur free road fuel David Hurley said he had discussed this proposal with Matt Vincent and it had been agreed there was no reason for FBHVC to respond as the amount of fuel used in older vehicles was so little that no consideration would be given to special treatment. The new standards might cause “memory” problems for older seals, but that would be a one-off problem.
n. proposed changes to the on-road and off-road motor event regulations The secretary apologised for running so short of time that he had been unable to circulate a draft response to anyone other than the chairman. The response had used the form provided by DfT, and was supportive of DfT efforts to simplify regulations, but noted that there should be a requirement to justify any fee increases.
B. Current consultations
a. Revisions to MoT Testing Guide, 6th Edition (30/6) It was agreed this consultation (on guidelines for MoT testing stations about personnel, equipment etc.) was outside FBHVC’s remit.
b Revisions to MoT Inspection Manual – testing of number plates (7/7) The consultation dealt with new sections to the inspection manuals for motor cycles, cars & light commercials and private buses. It had been noted that the guidelines referred to date of vehicle registration, rather than date of first use, and that it referred to the need for “white on black background” plates for pre-1973 vehicles not fitted with reflective plates whereas some buses and quality cars had plates made by reversing the letters out of black on a glass panel which was then lit from behind. It was agreed the secretary should draft a response highlighting these problems for approval by the chairman. DH
c. DVLA consultation on fee proposals (21/7) After some debate, it was agreed that FBHVC should respond to this latest consultation by opposing the whole principle of an Administration Charge. It was also agreed that the response should make it clear that if such a charge had to be imposed, it would be more equitable if it was applied to all VED transactions, and not be attached to the MoT test fee. It was agreed that the secretary should draft the response in conjunction with the chairman, aiming to send copies to all sub-committee members by 14 July. JW/DH
d. any other new consultation Sandy Hamilton said he had heard there was likely to be a new consultation on the cherished number transfer process aimed at improving the system to speed up non-controversial transfers.
C. Other Matters
a. occasional sales No further news.
b. use of red diesel/TVO in tractors The secretary said he had been in touch with the official at HM Revenue and Customs who had said he was still waiting a ruling on TVO from “management”. There was a strong hint that the outcome would be satisfactory.
c. other matters The secretary said DVLA had recently published a new leaflet INF 201 concerning the first registration of tractors. Obviously designed for the benefit of those wishing to register new or nearly new tractors, this suggested it was illegal to use a tractor without a safety cab. The secretary said he had established that this related only to tractors first used after 1976, and that those made before 1977 could thus be registered without evidence of being fitted with a compliant cab. DVLA Local Offices were being informed.
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4. All Party Parliamentary Historic Vehicle GroupGeoff Smith reported on the recent meeting with the All Party Parliamentary Historic Vehicle Group, and had been pleased to note that John Cryer had been present, albeit as a researcher. David Hurley said the meeting had covered disabled access and low emission zone for London, and he had provided a briefing document on these topics. Geoff Smith said that Greg Knight would be following up on the three items on the agenda relating to heritage. The Minister of State for Transport had been invited to attend the post-Beaulieu committee meeting dinner. The secretary noted this and agreed to check arrangements. JW
5. European Report
David Davies said he would check on the status of the FIVA Drivers’ Code with a view to ensuring it had been published before any possible mention in the Highway Code. DD
David outlined concerns about emissions testing in Austria that had caused problems for the owner of an LE Velocette – the suggestion was that there were no concessions on standards for older machines in Austria, and that led to a concern at the possibility of a hardening of attitude towards historic vehicles. All present felt this was most likely to be an internal Austrian matter, but it was agreed David should mention the concerns to Andrew Turner of EPPA in case it was the first symptom of difficulties ahead. DD
The secretary said he had been alerted to a new piece of French law, a decree passed in May, that apparently required those organising events for motor vehicles to notify authorities of their plans. It was agreed that David Davies should ask Patrick Rollet of the French Federation for a summary so that a note could appear in the next newsletter to alert UK clubs that organise events in France to the new requirements. DD
6. DVLA
Sandy Hamilton said he had no particular DVLA items other than to report that recent delays in handling V765 applications had been the result of a change to working procedures at DVLA, and that things were now getting back to normal.
7. Implementation of measures in Vision 2005-10
David Hurley said that John Billard had agreed (in principle) to take on the role as his deputy.
8. Other matters David Hurley said he was concerned to find that the testing regulations for private buses made no concession for those early buses with no front-wheel brakes. Other commercial vehicles of that period were exempt from testing. It was agreed that David should raise the matter with VOSA with a view to resolving a problem that would effectively prevent any bus with brakes only on the rear axle (typically those made prior to 1930) being used. DH
David Hurley mentioned an article by Michael Worthington Williams in the current issue of The Automobile which was effectively critical of DVLA staff. He said he planned to respond setting the record straight and pointing out the registration problem referred to would never have happened if the owner of the vehicle concerned had kept his paperwork up to date. DH9. July/August Newsletter
The secretary reminded the meeting that the next newsletter would be printed by a new printer and would be the first in A5 format for some ten years. He said the printer was keen to have the first issue as far in advance as possible to give time to resolve any teething problems. Rosy Pugh asked for material by Monday 10 July if at all possible. She showed the meeting three possible cover designs – a design using the style of the FBHVC letter head as a frame for a photograph was agreed.
.………………………………………………Chairman Jim Whyman,Secretary.