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Member's response to the DfT consultation

You have only until Wednesday 2nd November 2016 to send the DfT your views on their proposals to end the MOT test for vehicles up to 1977. It's essential you examine the classic car MOT proposals from the DfT and if you feel they are unwise or not safe, or indeed if you agree with them, then please express your views using the DfT's online smart survey as part of their consultation process.

What are the DfT proposals?
See the DfT webpage with links to briefing documents, an impact assessment and an online smart survey form. More

What is the EU Directive on Roadworthiness Testing?
See the EU website. More

EU proposals on roadworthiness testing
See an FBHVC report. More

See our previous NEWS item raising concerns over the rushed DfT consultation on their proposals to end MOTs for vehicles up to 1977. More

Comment
Many V8 enthusiasts might feel the proposed MOT exemption for classic cars built up to and including 1977 is good news and would result in their not having the drudgery and expense of taking their classic car for an MOT test every year. Most classic car enthusiasts maintain their cars well and the available data indicates a statistically insignificant number of accidents are caused by defects in historic vehicles, so why argue for the continuation of a test?

Well the case for retaining an annual MOT test in some form is it provides a discipline so a classic car enthusiast does tend to either check the car themselves before the test or they have the car serviced by a specialist, so any issues can be spotted and dealt with.

What should an MOT test of a classic car cover? I suggest a check of the vehicle identity, brakes (for example brake efficiency which could highlight any potential problems), steering, tyres, lights and all running gear, plus checking for corrosion where it affects the structure of the vehicle. Those checks are all essentially safety related areas of concern.

It's clear enthusiasts' views are split over the DfT MOT exemption proposals.

Victor Smith, V8 Webmaster

Posted: 161027

The views expressed in a survey response sent to the DfT by a well informed fellow V8 member are particularly interesting. In summary he:
> Supports exempting all 30 year old vehicles from the full test, and introducing a basic roadworthiness safety check for them.
> Does not support the idea of imposing an annual mileage limit on historic vehicles (VHIs) exempted from MOT testing?
> Supports continuing with a purely age-related exemption, a system that is well understood, suited to UK needs and produces a statistically insignificant number of accidents caused by defects in historic vehicles.

Survey response by a fellow V8 member:

DfT Consultation, September 2016
Vehicles of Historical Interest - Exemptions from Annual Roadworthiness Testing
Firstly I should like to say that I consider that this consultation has been overtaken by events; the Government has indicated its intention to invoke Article 50 by March 2017, with the result that the UK will leave the EU no later than March 2019. The EU Directive on Roadworthiness testing does not require implementation until May 2018, so the extensive changes proposed are in fact necessary under EU law for less than one year. It is already clear that the remaining EU nations will not be treating the UK as a full participating member during the Brexit negotiations, indeed have already ceased to do so, for instance holding discussions without UK participation. It thus seems excessively legalistic to insist on implementing the directive, which is largely drafted to suit the requirements of other EU members and is not needed from a UK perspective. This burden of regulation is entirely unnecessary and should be avoided.

Secondly there are some strange unsubstantiated assumptions which appear in the policy objectives set out in the impact statement. It is not at all obvious that only unmodified original vehicles are of genuine historical interest, in fact modified vehicles may be of equal or greater interest and may be unique, whereas original vehicles of the same type may be plentiful. Similarly, why should any assumption be made that modified vehicles are likely to be less well maintained? An owner who has gone to the trouble of modifying his vehicle is surely likely to also be concerned to maintain it. The suspicion arises that these unjustified assumptions have been made to bolster the case for the changes required by the Directive.

Responses made to the thirteen questions set out on the DfT online smart survey form:

Question 1: Do you agree with exempting 40 year old VHIs from annual testing plus introducing a VHI certification process to ensure a vehicle has not been substantially changed (option 3 in the proposals)?
No, I would favour exempting all 30 year old vehicles from the full test, and introducing a basic roadworthiness safety check for them. There is no basis for distinguishing modified vehicles from unmodified, and in fact considerable practical difficulties in deciding whether vehicles have been modified.

Question 2: Do you believe that we should allow exemptions for 30 year old vehicles rather than 40 year old vehicles?
Yes, as stated above.

Question 3: Do you agree that there are good safety reasons to exempt 40 year old rather than 30 year old VHIs from testing?
No, no data is provided to demonstrate that, in fact the numbers involved are so low as to be quite insignificant, even though for pre-1960 vehicles they include modified vehicles, supposedly more dangerous.

Question 4: Do you agree with the option of using Driver and Vehicle Licensing Agency’s (DVLA) 8 point rule as a way of defining the ‘substantial change’ provision in the new directive? If no can you suggest an alternative method.
No, this rule was drafted to deal with ‘reconstructed classics’ and is quite inappropriate for the purpose. There should be no distinction made between so-called VHI and other vehicles. If the DfT is determined to follow the directive, the assumption should be made that all vehicles are VHI unless the owner states that they are not.

Question 5: If we use DVLA’s 8 point rule, how many VHIs might fail to prove they have not undergone substantial changes?
I do not believe that anyone is in a position to even hazard a guess at that number.

Question 6: Do you agree with the assumption that the majority of VHIs used for business purposes will continue to have an MOT test to ensure they remain roadworthy and to keep insurance premiums down?
Yes and of course there are requirements imposed by operator’s licensing regulations.

Question 7: If we decide that VHIs should undergo a basic VHI roadworthiness ‘safety’ test do you agree that the test should only check vehicle identity, brakes, steering, tyres and lights only? If not what should the test cover?
The test should include all running gear and corrosion where it affects the structure of the vehicle.

Question 8: Do you agree that the exemption should apply to all VHIs or should we continue to test certain classes of VHIs, e.g. heavy goods vehicles and public service vehicles?
These vehicles are subject to requirements imposed by operator’s licensing regulations.

Question 9: Do you agree that we should not take into account any vehicle modifications made before 1988?
Yes, or after 1988 either.

Question 10: Do you agree that most privately owned VHIs are kept in a well maintained condition by their owners?
I would say that most privately owned historic vehicles are kept in a well maintained condition by their owners, whether or not they would fall to be classified as VHIs.

Question 11: Do you agree that an annual mileage limit should be imposed on VHIs exempted from testing? If yes, what annual mileage limit should be imposed?
No, this is not something even required by the directive. This is gold-plating of the most extreme kind and totally undesirable. It would require regulations to be drafted requiring the fitment of odometers of some specified accuracy and further regulations to prohibit adjusting them and account to be taken of the need sometimes to repair or replace them. A mass of regulation would need to be created for no discernible need.

Question 12: Do you agree with the impact assessment published alongside this document? Please provide any information you have that will help us to more precisely estimate costs and benefits.
I have commented above on the unsubstantiated and implausible assumptions made in the policy objectives.

Question 13: Are there any other options you think we should consider in connection with testing exemptions for VHIs? (including documentation)
Continue with a purely age-related exemption, a system that is well understood, suited to UK needs and according to the data shown produces a statistically insignificant number of accidents caused by defects in historic vehicles.